Griño v. Department of Agrarian Reform
REITERATIONFacts
The Antecedents: Juan Griño, Sr. (Griño) was the owner of a 9.35-hectare agricultural land (Lot 1505-B) in Leganes, Iloilo, and a 50-hectare land in Sara, Iloilo, which he mortgaged to the Development Bank of the Philippines (DBP). Presidential Decree No. 27 (PD 27) was issued, emancipating tenants from the soil and transferring ownership of land. Griño's 9.35-hectare land was covered by PD 27, and Certificates of Land Transfer (CLTs) were issued to his tenants. Griño filed a petition to cancel these CLTs, arguing they were issued without due process and offering other lands in lieu. He later ceded his 50-hectare land to DBP via dacion en pago to settle his loan. Griño died in 1985, followed by his wife in 1988. Republic Act 6657 (CARL) took effect in 1988. Procedural History: The DAR Regional Director dismissed Griño's petition for cancellation of CLTs in 1989, citing Letter of Instructions No. 474 (LOI 474) and noting Griño owned 50 hectares of untenanted land, disqualifying him from exemption/retention. Emancipation Patents (EPs) were later issued to the tenants. Petitioners (heirs) filed an application for retention in 1997 under Section 6 of CARL. The DAR Regional Director dismissed this application, stating the conveyance of the 50-hectare land to DBP in 1985 had no legal effect as it occurred after the land was subjected to Operation Land Transfer under PD 27. The DAR Secretary denied the heirs' appeal, holding that Griño was not entitled to retention under PD 27 and thus his heirs could not claim it under CARL. The Court of Appeals affirmed the DAR Secretary's order, ruling that Griño had no right of retention and that the heirs were bound by the finality of the DAR's 1989 order and were guilty of laches. The Court of Appeals also denied the heirs' motion for reconsideration. The Petition: Petitioners filed a petition for certiorari with the Supreme Court, faulting the Court of Appeals for grave abuse of discretion in refusing to recognize their constitutional right of retention and in insisting that they lost their right due to the finality of the Maraya Order, despite alleged irregularities and new evidence.
Issue(s)
Whether the petition for certiorari under Rule 65 was the proper remedy. Whether the heirs of Juan Griño, Sr. are entitled to the right of retention over the 9.35-hectare land. Whether the heirs are bound by the DAR's 1989 order dismissing the petition for cancellation of CLTs. Whether the heirs are guilty of laches or estopped from questioning the denial of retention rights.
Ruling
The petition is DISMISSED. The Court of Appeals did not commit grave abuse of discretion. The heirs are not entitled to the right of retention. The heirs are bound by the finality of the DAR's 1989 order and are guilty of laches.
Ratio Decidendi
On the propriety of the remedy: The petition for certiorari under Rule 65 was filed beyond the reglementary period for filing a petition for review on certiorari under Rule 45. Certiorari cannot be used as a substitute for a lost appeal. While the Court has discretion to treat a Rule 65 petition as a Rule 45 petition, no justification was proffered for the delay, warranting a liberal application of the rules. Therefore, the petition is technically dismissible on procedural grounds. On the right of retention: Juan Griño, Sr. was not entitled to retain any portion of his tenanted riceland under PD 27 because he owned 50 hectares of other agricultural land (coconut land) at the time PD 27 took effect. LOI 474, which provided for exemptions, did not grant retention rights to landowners in Griño's situation. Consequently, his heirs, as successors-in-interest, cannot claim retention rights under either PD 27 or RA 6657 over the same property. The conveyance of the 50-hectare land to DBP in 1985 was irrelevant as it occurred after the land was already covered by PD 27. On being bound by the DAR's 1989 order: The DAR Regional Director's Order dated September 25, 1989, dismissing Griño's petition for cancellation of CLTs, became final and executory. The heirs failed to appeal this dismissal within the reglementary period. The Court of Appeals correctly ruled that res judicata applies, as the DAR, as the agency vested with authority, had already ruled on the merits of Griño's petition, laying to rest the issue of retention. The subsequent issuance of Emancipation Patents further solidified the tenants' ownership. On laches and estoppel: The heirs are guilty of laches for attempting to resurrect the retention issue seven and a half years after the denial of Griño's petition became final. Laches is the failure to do what could have been done earlier within an unreasonable and unexplained length of time. Furthermore, the DAR cannot be faulted for the lack of substitution of heirs upon Griño's death; it was the duty of the heirs to notify the tribunal of the litigant's death and attend to the estate. Allowing the heirs to reopen the case after such a long period would be unjust to the tenant-beneficiaries who are now full owners of the land.
Main Doctrine
A landowner who failed to exercise his retention right under Presidential Decree No. 27 cannot avail of the right of retention over the same land under the Comprehensive Agrarian Reform Law. Furthermore, heirs are bound by the final rulings of administrative agencies concerning their predecessor's rights and are subject to the doctrines of res judicata and laches if they fail to act within reasonable time.