Levardo v. Yatco
REITERATIONFacts
The Antecedents: This case involves two separate but related disputes concerning agricultural lands in Binan, Laguna. In the first instance, Asuncion Belizario donated a 4.3488-hectare parcel of land to Tomas Yatco, which was tenanted by Aguido Levardo. Aguido, along with his children, executed a sworn statement waiving their tenancy rights and accepting P2,000,000.00 as disturbance compensation before Aguido's death. Subsequently, Tomas Yatco sold the land to Gonzalo Puyat and Sons, Inc. In the second instance, Leoncio Yatco owned a 4.2406-hectare parcel tenanted by Francisco Levardo and his son Hernando. Hernando, with his father's concurrence, also executed a sworn statement waiving their tenancy rights and receiving P2,417,142.00 in disturbance compensation before Leoncio sold the land to Gonzalo Puyat and Sons, Inc. Procedural History: The heirs of Aguido Levardo, led by Angelita Levardo, and Hernando Levardo, along with his father Francisco, filed separate complaints with the Provincial Agrarian Reform Adjudicator (PARO) seeking to annul the deeds of donation and sale, and to declare the waivers of tenancy rights void. The PARO initially ruled in favor of the Levardo heirs, declaring the waivers and deeds void and ordering the issuance of Emancipation Patent Titles. However, upon reconsideration, the PARO set aside its previous decisions, declared the waivers of tenancy rights valid, upheld the deeds of donation and sale, and ruled that the lands were outside Operation Land Transfer (OLT) coverage and untenanted. The Levardo heirs appealed to the Department of Agrarian Reform Adjudication Board (DARAB), which initially reversed the PARO's order but later, upon reconsideration, reinstated the PARO's decision, affirming the validity of the waivers and the sale, and the exclusion of the lands from OLT coverage. The Levardo heirs then appealed to the Court of Appeals (CA), which affirmed the DARAB's resolution. The CA's decision was not subject to a motion for reconsideration, leading to the present petition. The Petition: The petitioners seek review on certiorari under Rule 45 of the Rules of Court, challenging the Court of Appeals' decision. Their primary arguments center on whether Presidential Decree No. 27 (P.D. No. 27) covered the lands in dispute, thereby deeming their predecessors as owners. They question the validity of the waivers of rights, particularly if Certificates of Land Transfer (CLTs) were issued and subsequently cancelled without due process. They also question the landowner's right to convey the lands to respondent Puyat and Sons, Inc. if they were indeed covered by P.D. No. 27. The core of their petition is that their predecessors were deemed owners under P.D. No. 27, and any waivers or sales should be nullified. The Supreme Court, however, found that the lands, being seven hectares or less, were not covered by P.D. No. 27, and that the waivers were validly executed, especially since no CLTs were proven to have been issued. The Court also noted that the disturbance compensation received was advantageous to the petitioners' families, preventing them from reneging on their agreements.
Issue(s)
Whether Presidential Decree No. 27 covers the lands in dispute, deeming the tenant-farmers as owners. Whether the predecessors of the petitioners paid for the lands pursuant to Executive Order No. 228. Whether Certificates of Land Transfer (CLTs) were issued in favor of the petitioners' predecessors, and if so, whether they nullify the waivers of rights, and if such CLTs were legally cancelled without due process. Whether the landowner could legally convey the rice lands covered by P.D. No. 27, of which the petitioners' predecessors were allegedly absolute owners, in favor of respondent Puyat and Sons, Inc.
Ruling
The petition is denied for lack of merit. The September 27, 2004 Decision of the Court of Appeals in CA-G.R. SP No. 69220 is affirmed.
Ratio Decidendi
On the coverage of Presidential Decree No. 27: The Court held that the lands in dispute do not fall under the coverage of P.D. No. 27. The DAR Memorandum dated July 10, 1975, categorically states that tenanted rice and/or corn lands of seven hectares or less shall not be covered by Operation Land Transfer (OLT). In DARAB Case No. 3361, the land was 4.3488 hectares, and in DARAB Case No. 3362, it was 4.2406 hectares, both falling below the seven-hectare threshold. Furthermore, while Letter of Instruction No. 474 (LOI No. 474) allows for coverage of lands less than seven hectares if the landowner owns other agricultural lands exceeding seven hectares or urban lands providing adequate income, the Court found no record or evidence presented by the petitioners to establish such ownership by the landowners. The burden of proof was on the petitioners to show that the landowners owned other properties in excess of seven hectares, which they failed to do. Therefore, the primary condition for OLT coverage was not met. On the validity of the waivers of tenancy rights and disturbance compensation: The Court found that the waivers of tenancy rights executed by Aguido Levardo and Hernando Levardo were valid and enforceable. The "Pinanumpaang Salaysay" clearly indicated the tenants' voluntary surrender of their rights "dahil sa aming kagustuhang umiba ng hanap buhay ng higit ang pagkikitaan kaysa panakahan" (due to our desire to change livelihood for a better income than farming). The substantial disturbance compensation paid by the landowners (₱2,000,000.00 to Aguido and ₱2,417,142.00 to Hernando) was deemed advantageous to the families of the petitioners, enabling them to pursue other sources of livelihood. The Court noted that the petitioners did not refute the authenticity of these waivers, which were duly notarized, thus enjoying the presumption of regularity. The Court emphasized that the protective mantle of social justice was not intended to disregard the rights of landowners, especially when agreements were voluntarily entered into and substantially compensated. On the existence and effect of Certificates of Land Transfer (CLTs): The Court affirmed the DARAB's finding that there was no record to show that CLTs were actually issued to the petitioners or their predecessors. The documents presented by the petitioners, consisting of photocopies of a "Masterlist of Tenants issued CLTs," were deemed to have no probative value. One document was a certified xerox copy, while the other was not authenticated, making its source suspect. These documents were insufficient to prove the issuance of CLTs, which would have been the best evidence. Moreover, the Court reiterated that even if CLTs were issued, they do not vest ownership in the farmer/grantee; they merely evidence recognition of qualification to await the mechanism for ownership acquisition under P.D. No. 27. Since the lands were found not to be covered by P.D. No. 27, any supposed CLTs would be without basis. On the legality of the conveyance of lands: Given that the lands were not covered by P.D. No. 27 and the waivers of tenancy rights were valid, the Court concluded that the conveyances made to respondent Puyat and Sons, Inc. were legal and valid. The petitioners could not renege on their agreements with the respondents, especially after receiving substantial disturbance compensation. The Court found no basis to overturn the findings of the PARO and DARAB, which were affirmed by the Court of Appeals, that the waivers were valid and the lands were outside OLT coverage. Therefore, the landowners were legally entitled to convey their properties.
Main Doctrine
Lands with seven hectares or less are not covered by Operation Land Transfer (OLT) under Presidential Decree No. 27, and voluntary waivers of tenancy rights, supported by disturbance compensation, are valid and binding, especially when no Certificates of Land Transfer (CLTs) were issued.