FACTS:

In this case, a Certificate of Land Transfer (CLT) was issued in favor of the respondent over a 5,000 square meter lot. In 1978, the respondent passed on the subject land to the petitioner for the amount of P5,800.00 and P200.00 worth of rice. There was a dispute as to whether this transaction was a verbal mortgage or a sale. As a result of the transfer, the DAR officials authorized the survey and issuance of an Emancipation Patent, leading to the issuance of a Transfer Certificate of Title in favor of the petitioner.

In 1988, the respondent filed a complaint against the petitioner for the purpose of redeeming the subject land. The case was referred to the Department of Agrarian Reform (DAR) regional office, and after an investigation, it was recommended that the CLT remain in the name of the respondent and that the money loan be returned to the petitioner. However, the petitioner insisted that the subject land had been sold to him and requested the DAR to cancel the CLT in the respondent's name.

Further investigations were conducted, and the DAR Regional Director issued an order finding the respondent's act of surrendering the land as constituting abandonment and denied the respondent's prayer for redemption. The respondent appealed the case to the DAR Central Office, which reversed the order of the DAR Regional Director and ordered the petitioner to return the subject land to the respondent. The petitioner's subsequent appeals were all denied.

The Court of Appeals ruled that the transfer of the subject land to the petitioner is void and should be returned to the respondent. The appellate court also held that the respondent had not effectively abandoned the property and noted that he still held the Certificate of Land Transfer covering the land.

Petitioner raises several issues, including whether there was a valid abandonment by the respondent, whether the conveyance of the land to the petitioner constitutes a valid abandonment, whether the petitioner's continuous possession has ripened into ownership, and whether the issuance of an emancipation patent and transfer certificate of title has validated ownership. The main issue is whether the respondent abandoned the subject property, thereby making it available to other qualified farmer-grantees.

ISSUES:

1. Whether or not there is a valid abandonment of the subject property made by respondent.

2. Whether the conveyance of the subject property by respondent to petitioner constitutes a valid abandonment, thereby making the property available for transfer to other qualified farmers.

3. Whether the continuous possession and cultivation of the subject property by petitioner since 1976 up to the present has ripened into ownership of the property.

4. Whether the issuance of an emancipation patent and transfer certificate of title in the name of petitioner has validated and legitimized possession and ownership of the disputed property.

RULING:

1. The Supreme Court ruled in favor of the respondent, holding that there was no valid abandonment of the subject property. Consequently, the transfer of the subject property to the petitioner is void and the property should be returned to the respondent.

PRINCIPLES:

• Agrarian laws must be interpreted liberally in favor of the grantee to achieve the clear intent of these laws, which is to provide a dignified existence for small farmers and make them more independent, self-reliant, and responsible citizens.

• In cases involving agrarian reform and land distribution, the focus should be on the welfare of the farmers and the fulfillment of their rights.