Lacorda v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: Petitioners Felix Lacorda and Concordia A. Lacorda sold their homestead, measuring over 18 hectares, on April 2, 1975, to spouses Rolando and Cynthia Oliva for P53,888.30. Two years later, the Oliva spouses sold the same land to Dante Parcon for the same amount. Procedural History: On February 16, 1980, petitioners expressed their desire to repurchase the property for P53,888.30 and were ready to pay. When repurchase was not effected, petitioners filed suit in the defunct Court of First Instance of Davao to compel reconveyance. The Court of First Instance dismissed the complaint, upholding Dante Parcon's ownership. On appeal, the Intermediate Appellate Court affirmed the decision in toto. The Petition: Petitioners filed the instant petition with the Supreme Court seeking to reverse the decision of the Intermediate Appellate Court.
Issue(s)
Whether the petitioners, as homesteaders, are entitled to repurchase the homestead property within the statutory period, considering their intent regarding the land's use. Whether the findings of fact by the trial and appellate courts regarding the petitioners' intent are binding on the Supreme Court.
Ruling
The petition is dismissed. The decision of the Intermediate Appellate Court affirming the dismissal of the complaint by the Court of First Instance is upheld.
Ratio Decidendi
On the issue of repurchase for profit: The Court held that while the offer to repurchase was made within the statutory period, both the trial and appellate courts found as a fact that the petitioners did not genuinely intend to derive their livelihood from the land, but to resell part of it for a substantial profit. The Court reiterated that homesteaders should not exploit the Public Land Law to recover land only to dispose of it again at a greater profit, undermining the law's purpose to provide a home and livelihood. Therefore, the right to repurchase, though exercised within the legal timeframe, was denied based on the petitioners' ulterior motive. On the binding nature of factual findings: The Court affirmed the factual findings of the lower courts, stating that the Supreme Court generally does not disturb the factual findings of the trial and appellate courts, especially when they are unanimous and supported by evidence. The finding that the petitioners intended to resell the property for profit was a factual determination made by both the Court of First Instance and the Intermediate Appellate Court. Absent any showing of grave abuse of discretion or that the findings were not supported by evidence, these factual conclusions are binding on the Supreme Court. The petition did not present any compelling reason to deviate from this rule.
Main Doctrine
Homesteaders are not allowed to repurchase land solely for the purpose of reselling it at a profit, as this contravenes the salutary policy behind the Public Land Act which aims to provide a home and livelihood for the homesteader.