Case Digest: Heirs of Castro v. Lozada
G.R. No. 163026 : August 29, 2012
HEIRS OF ARCADIO CASTRO, SR., represented by ARCADIO CASTRO, JR., Petitioners, v. RENA TO LOZADA, FELIPE CRUZ, ONOFRE INONCILLO, ALFREDO FRANCISCO, LIBERATO FRANCISCO, FELIPE DE LA CRUZ, HERNANDO HERRERA, GERARDO MIRANDA, FELIX INOVERO, ARCADIO IDAGO and RESTITUTO DE LA CRUZ,Respondents.
VILLARAMA, JR., J.:
FACTS:
Respondents are the occupants/tillers of a rice land situated at Upig, San Ildefonso, Bulacan designated as Lot No. 546, with an aggregate area of 274,180 square meters. In April 1977, respondents filed their respective applications to purchase Lot No. 546 with the DAR-Bulacan Provincial Office. Since the 1940’s, respondents recognized Arcadio Castro, Sr. as their landlord who claimed to be the original tenant of the land. However, records of the DAR Region III Office showed that the registered claimant of Lot No. 546 is one “Arcadio Cruz.”
The processing of respondents’ applications was stalled due to the opposition of Arcadio Castro, Sr. who submitted photocopies of certain official receipts and the Affidavit executed by his sister-in-law, Jacobe Galvez. In the said affidavit, Jacobe Galvez attested that upon the instruction of her brother-in-law, she paid on September 27, 1944 the “cost and rental” of Lot No. 546 in the amount of P5,091.80. Additional payments were supposedly made in 1961 in the amounts of P1,181.77 and P530.52. Jacobe Galvez further explained that while the receipts were issued in her name, her payments were made for and in behalf of her brother-in-law who actually owns the land and is the one receiving rentals or share in the harvest from the tenants. Thus, Castro claimed that he has vested rights over the said lot.
When the matter was elevated to the Regional Director, the latter ruled that there is no evidence to show that registrant “Arcadio Cruz” and claimant Arcadio Castro, Sr. is one and the same person, and no legal action was taken to correct the discrepancy in name as to vest unto the claimant legal personality to be the proper party-in-interest. On appeal to the DAR Secretary, the latter affirmed the Regional Director’s ruling. Both the Office of the President and the Court of Appeals also found that the heirs of Castro failed to establish their claim.
ISSUE: Whether or not the heirs of Castro, Sr. has acquired vested right over Lot 546?
HELD: The Court denies the petition.
CIVIL LAW: vested right
A vested right is defined as one which is absolute, complete and unconditional, to the exercise of which no obstacle exists, and which is immediate and perfect in itself and not dependent upon a contingency. The term “vested right” expresses the concept of present fixed interest which, in right reason and natural justice, should be protected against arbitrary State action, or an innately just and imperative right which enlightened free society, sensitive to inherent and irrefragable individual rights, cannot deny. To be vested, a right must have become a title—legal or equitable—to the present or future enjoyment of property.
A party claiming a right granted or created by law must prove his claim by competent evidence. He must rely on the strength of his evidence and not on the weakness of that of his opponent.
LABOR LAW: agrarian reform; social justice
Finally, the Court holds that no reversible error was committed by the CA when it ruled that the order of DAR Regional Director giving due course to the application of respondents is consistent with the agrarian reform policy under the 1987 Constitution. Whereas C.A. No. 539 enacted in 1940 authorized the Government to acquire private lands and to subdivide the same into home lots or small farms for resale to bona fide tenants, occupants or private individuals who will work the lands themselves, the social mandate under the 1987 Constitution is even more encompassing as it commands “the Congress to give the highest priority to the enactment of measures that protect and enhance the right of all the people to human dignity, reduce social, economic, and political inequalities, x xx”
To achieve such goal, “the State shall, by law, undertake an agrarian reform program founded on the right of farmers and regular farm workers, who are landless, to own directly and collectively the land they till or, in the case of other farm workers, to receive a just share of the fruits thereof.” Moreover, C.A. No. 539 being a social legislation, this Court has previously declared that “in the construction of laws that find its origin in the social justice mandate of the Constitution,” the constant policy is “ to assure that its beneficient effects be enjoyed by those who have less in life.”
Petition is DENIED.
HEIRS OF ARCADIO CASTRO, SR., represented by ARCADIO CASTRO, JR., Petitioners, v. RENA TO LOZADA, FELIPE CRUZ, ONOFRE INONCILLO, ALFREDO FRANCISCO, LIBERATO FRANCISCO, FELIPE DE LA CRUZ, HERNANDO HERRERA, GERARDO MIRANDA, FELIX INOVERO, ARCADIO IDAGO and RESTITUTO DE LA CRUZ,Respondents.
VILLARAMA, JR., J.:
FACTS:
Respondents are the occupants/tillers of a rice land situated at Upig, San Ildefonso, Bulacan designated as Lot No. 546, with an aggregate area of 274,180 square meters. In April 1977, respondents filed their respective applications to purchase Lot No. 546 with the DAR-Bulacan Provincial Office. Since the 1940’s, respondents recognized Arcadio Castro, Sr. as their landlord who claimed to be the original tenant of the land. However, records of the DAR Region III Office showed that the registered claimant of Lot No. 546 is one “Arcadio Cruz.”
The processing of respondents’ applications was stalled due to the opposition of Arcadio Castro, Sr. who submitted photocopies of certain official receipts and the Affidavit executed by his sister-in-law, Jacobe Galvez. In the said affidavit, Jacobe Galvez attested that upon the instruction of her brother-in-law, she paid on September 27, 1944 the “cost and rental” of Lot No. 546 in the amount of P5,091.80. Additional payments were supposedly made in 1961 in the amounts of P1,181.77 and P530.52. Jacobe Galvez further explained that while the receipts were issued in her name, her payments were made for and in behalf of her brother-in-law who actually owns the land and is the one receiving rentals or share in the harvest from the tenants. Thus, Castro claimed that he has vested rights over the said lot.
When the matter was elevated to the Regional Director, the latter ruled that there is no evidence to show that registrant “Arcadio Cruz” and claimant Arcadio Castro, Sr. is one and the same person, and no legal action was taken to correct the discrepancy in name as to vest unto the claimant legal personality to be the proper party-in-interest. On appeal to the DAR Secretary, the latter affirmed the Regional Director’s ruling. Both the Office of the President and the Court of Appeals also found that the heirs of Castro failed to establish their claim.
ISSUE: Whether or not the heirs of Castro, Sr. has acquired vested right over Lot 546?
HELD: The Court denies the petition.
CIVIL LAW: vested right
A vested right is defined as one which is absolute, complete and unconditional, to the exercise of which no obstacle exists, and which is immediate and perfect in itself and not dependent upon a contingency. The term “vested right” expresses the concept of present fixed interest which, in right reason and natural justice, should be protected against arbitrary State action, or an innately just and imperative right which enlightened free society, sensitive to inherent and irrefragable individual rights, cannot deny. To be vested, a right must have become a title—legal or equitable—to the present or future enjoyment of property.
A party claiming a right granted or created by law must prove his claim by competent evidence. He must rely on the strength of his evidence and not on the weakness of that of his opponent.
LABOR LAW: agrarian reform; social justice
Finally, the Court holds that no reversible error was committed by the CA when it ruled that the order of DAR Regional Director giving due course to the application of respondents is consistent with the agrarian reform policy under the 1987 Constitution. Whereas C.A. No. 539 enacted in 1940 authorized the Government to acquire private lands and to subdivide the same into home lots or small farms for resale to bona fide tenants, occupants or private individuals who will work the lands themselves, the social mandate under the 1987 Constitution is even more encompassing as it commands “the Congress to give the highest priority to the enactment of measures that protect and enhance the right of all the people to human dignity, reduce social, economic, and political inequalities, x xx”
To achieve such goal, “the State shall, by law, undertake an agrarian reform program founded on the right of farmers and regular farm workers, who are landless, to own directly and collectively the land they till or, in the case of other farm workers, to receive a just share of the fruits thereof.” Moreover, C.A. No. 539 being a social legislation, this Court has previously declared that “in the construction of laws that find its origin in the social justice mandate of the Constitution,” the constant policy is “ to assure that its beneficient effects be enjoyed by those who have less in life.”
Petition is DENIED.