Heirs of Dela Corta v. Alag-Pitogo
REITERATIONFacts
The Antecedents: This case concerns Lot No. 50, a portion of Lot 11421 in Ormoc City, Leyte. Originally registered to Agapito Pongos, the lot was awarded to the late Valeriano C. Dela Corta, Sr. (Valeriano) in 1974 under Presidential Decree No. 27. Valeriano died before the Transfer Certificate of Title was issued in his name in 1998. The dispute arose when Rebecca Alag-Pitogo (respondent) filed a petition for reallocation of the subject lot, asserting it was erroneously awarded to Valeriano. Respondent's claim was based on a Regional Trial Court decision in CAR Case No. 1726, which allegedly disqualified Valeriano as a farmer beneficiary and designated Guillerma Alag, respondent's mother, as the qualified beneficiary for a portion of the lot. Guillerma subsequently waived her rights to this portion in favor of the respondent. Procedural History: The respondent's petition for reallocation was granted by the Department of Agrarian Reform (DAR)-Region VIII on August 9, 2007. Valeriano's heir, Pedro C. Dela Corta (Pedro), filed a motion for reconsideration, asserting his peaceful possession and cultivation of the lot since Valeriano's death, but this was denied, and the DAR-Region VIII's order became final. Subsequently, respondent filed a petition before the Department of Agrarian Reform Adjudication Board (DARAB) for the cancellation of Valeriano's Emancipation Patent. The DARAB Regional Adjudicator ordered the cancellation of the patent and directed the generation of a new title in favor of the respondent. Pedro's appeal to the DARAB Central Office was dismissed, as was his subsequent motion for reconsideration. The petitioners then filed a Petition for Review with the Court of Appeals (CA), which affirmed the DARAB's decision. The CA ruled that Valeriano's disqualification was established by a prior RTC decision and that the reallocation was from Guillerma to respondent, not directly from Valeriano. The CA also found that the petitioners were not indispensable parties and that Pedro had been afforded due process. The Petition: The petitioners, the heirs of Valeriano C. Dela Corta, Sr., have filed this Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the Decision and Resolution of the Court of Appeals. They argue that the DAR-Region VIII's Order, the DARAB Regional Adjudicator's Decision, and the DARAB Central Office's Decision are null and void due to lack of jurisdiction and violation of their constitutional right to due process. Specifically, they contend that they were indispensable parties who were not impleaded, thereby depriving the DAR and DARAB of jurisdiction and violating their right to be heard. They maintain that the CA erred in affirming the lower tribunals' decisions, which they believe were based on misrepresentations and fabricated evidence, and failed to properly consider their claims as heirs.
Issue(s)
Whether the DAR-Region VIII's Order dated August 9, 2007, was null and void for failure to implead indispensable parties and for violation of due process. Whether the DARAB lacked jurisdiction over the persons of the registered landowners and the subject matter. Whether the CA erred in affirming the DARAB decisions and denying the petitioners' appeal.
Ruling
The petition is denied. The Decision dated August 27, 2015, and Resolution dated July 20, 2016, of the Court of Appeals in CA-G.R. SP No. 08322 are affirmed.
Ratio Decidendi
On the alleged nullity of the DAR-Region VIII's Order and lack of indispensable parties, and the alleged violation of due process: The Court held that the heirs of Valeriano were not indispensable parties because Valeriano had already been disqualified as a farmer beneficiary by a final RTC decision. Therefore, their failure to be impleaded did not deprive the DAR-Region VIII of jurisdiction. Pedro was not denied due process because he had the opportunity to question the DARAB-Region VIII's judgment by filing a Motion for Reconsideration, which was heard and denied. On the alleged lack of jurisdiction: The Court reiterated that the failure to implead Valeriano or his heirs did not deprive the DAR agencies of jurisdiction because Valeriano and his heirs no longer had a legally recognized interest in the subject lot due to the final judgment disqualifying Valeriano. The jurisdiction of the DAR agencies was properly invoked by the respondent's petition for reallocation. The DAR agencies' findings, when supported by substantial evidence and affirmed by the CA, are binding on the Supreme Court. On the CA's decision and the finality of the DAR-Region VIII's Order: The Court emphasized that the Order dated August 9, 2007, granting the reallocation to respondent, had already attained finality. Pedro's motion for reconsideration was denied, and he failed to timely file an appeal from that denial. A Certificate of Finality was issued, making the decision immutable and unalterable. Public policy dictates that a prevailing party should not be denied the fruits of victory through subterfuge.
Main Doctrine
The heirs of a disqualified farmer beneficiary are not indispensable parties in a petition for reallocation of the subject lot, especially when the disqualification has attained finality and the heirs' interest is derived from the disqualified beneficiary.