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SAMUEL ESTRIBILLO v. DEPARTMENT OF AGRARIAN REFORM

FACTS:

This case involves a Petition for Review on Certiorari seeking the review and reversal of the Resolutions of the Court of Appeals. The petitioners, with the exception of two, are recipients of Emancipation Patents (EPs) over parcels of land located in Agusan del Sur. The two other petitioners are the surviving spouses of deceased recipients of EPs. The parcels of land were formerly part of a forested area that was denuded due to logging operations of respondent Hacienda Maria, Inc. (HMI). HMI acquired the land from the Republic of the Philippines through a sales patent and obtained title over three parcels of land. In 1972, Presidential Decree No. 27 was issued, mandating that tenanted rice and corn lands be brought under the Operation Land Transfer and awarded to farmer-beneficiaries. HMI requested that its landholdings be placed under the coverage of Operation Land Transfer, and petitioners and other occupants were allowed to cultivate the land. The Department of Agrarian Reform conducted a parcellary mapping of the land and approved the Parcellary Map Sketching (PMS) and Amended PMS. HMI actively participated in the proceedings and executed a Deed of Assignment of Rights in favor of petitioners. In 1984 to 1988, TCTs and EPs were issued to petitioners. In 1997, HMI filed petitions to declare erroneous coverage of a portion of its former landholdings and sought the cancellation of EPs awarded to petitioners. The Regional Agrarian Reform Adjudicator (RARAD) declared the TCTs and EPs void for the land not being devoted to rice and corn.

The petitioners in this case filed a motion for reconsideration after their Transfer Certificates of Title (TCTs) and Emancipation Patents (EPs) were ordered cancelled due to the land not being devoted to rice and corn and the absence of established tenancy relations when Presidential Decree No. 27 took effect. The motion was denied, and petitioners appealed to the Department of Agrarian Reform Adjudication Board (DARAB), which affirmed the decision. The Court of Appeals dismissed the petition for review on certiorari because the verification and certification of non-forum shopping was executed by one petitioner without the proper special power of attorney authorizing him to sign for the other petitioners. The Court of Appeals denied petitioners' motion for reconsideration, stating that their submission of the special power of attorney did not justify their belated compliance with the requirements of non-forum shopping. Petitioners then filed a petition to the Supreme Court, arguing that they complied with the certification against forum shopping requirement.

The case involves a petition for review on certiorari filed by Samuel A. Estribillo and other farmer-beneficiaries from a remote barangay in Agusan del Sur. The petitioners sought the nullification of a decision and resolution issued by the Department of Agrarian Reform Adjudication Board (DARAB) and the Court of Appeals, respectively.

In their petition, the petitioners claimed that they were not properly represented by their legal counsel in signing the Verification and Certification against Forum Shopping. They argued that the certification should have been signed by the petitioner or any of the principal parties, and not just by the counsel, unless authorized by a special power of attorney. They cited previous cases that emphasized the need for the petitioner or principal party to personally sign the certification.

The Court of Appeals, in its decision, relied on a seemingly conflicting case involving a different set of petitioners. In that case, the Supreme Court ruled that the certification was defective because it was only signed by one of the petitioners, and there was no showing of authorization from the co-petitioners. The Supreme Court in that case emphasized the need for strict observance of the rules and dismissed the petition.

However, the petitioners in the present case argued that their situation was different from the previous case. They claimed to be farmer-beneficiaries residing in a remote barangay, and it would be unreasonable to require them to personally sign the certification due to the distance they had to travel. They argued for reasonable cause for their failure to personally sign the certification.

ISSUES:

  1. Whether or not the petitioners sufficiently complied with Rule 7, Section 5 of the 1997 Rules of Civil Procedure concerning the Certification Against Forum Shopping.

  2. Whether or not the Emancipation Patents (EPs) and the corresponding Transfer Certificates of Title (TCTs) issued to the petitioners or to their successors-in-interest have become indefeasible.

RULING:

  1. Compliance with Certification Against Forum Shopping

    The Supreme Court ruled that petitioners have sufficiently complied with Rule 7, Section 5 of the 1997 Rules of Civil Procedure. The Court noted that the technical rules of procedure should be used to promote, not frustrate, justice. Given the remote locations and the logistical difficulties faced by the petitioners, the Court found justification to relax the rules on the certification against forum shopping.

  2. Indefeasibility of EPs and TCTs

    The Supreme Court held that Certificates of Title issued pursuant to Emancipation Patents are as indefeasible as TCTs issued in registration proceedings. The ruling emphasized that the TCTs issued to petitioners pursuant to their EPs acquire the same protection accorded to other TCTs and become indefeasible after one year from the issuance of the order for the issuance of the patent.

PRINCIPLES:

  • Certification Against Forum Shopping

    • Rule 7, Section 5 of the 1997 Rules of Civil Procedure requires compliance, but such compliance should be interpreted to promote substantial justice rather than strict procedural adherence.

  • Indefeasibility of Titles

    • Titles issued under administrative proceedings, such as Emancipation Patents, are as indefeasible as those issued under judicial registration proceedings.

    • The certificates of title become indefeasible upon the expiration of one year from the date of issuance of the order for the issuance of the patent.

  • Relaxation of Procedural Rules

    • Procedural rules may be relaxed in certain exceptional circumstances to achieve substantial justice.

    • The intent and spirit of agrarian reform laws favor the conservation of agricultural lands for farmer-beneficiaries, thereby promoting social justice.

  • Protection Under Torrens System

    • Emancipation Patents and Certificates of Land Ownership Award (CLOAs) are enrolled in the Torrens system and are entitled to the same protection as other registered titles.