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RODRIGO ALMUETE v. MARCELO ANDRES

FACTS:

The disputed property in this case is a parcel of agricultural land in San Vicente, Angadanan, Isabela, measuring approximately 72,587 square meters. In 1957, the land was awarded to petitioner Rodrigo Almuete by the National Resettlement and Rehabilitation Administration (NARRA). Almuete and his family farmed the land peacefully and exclusively for twenty-two years. Unbeknownst to Almuete, an Agrarian Reform Technologist named Leticia Gragasin filed a report in 1979 stating that Almuete had waived his rights as a NARRA settler due to his poor health and financial hardship. Gragasin recommended that the award in favor of Almuete be cancelled and the land be awarded to respondent Marcelo Andres. Andres filed a homestead application based on Gragasin's recommendation and representations that he acquired the land from Almuete. The Ministry of Agrarian Reform granted Andres a homestead patent. However, Almuete continued to cultivate and farm the land, unaware that the award in his favor had been cancelled and a homestead patent had been issued to Andres. In 1988, ownership of the land was transferred to Andres. Thereafter, Andres, accompanied by armed individuals, entered the land and claimed exclusive ownership and possession, destroying trees and crops. Almuete filed an action for reconveyance and recovery of possession against Andres. The trial court ruled in favor of Almuete, declaring him the rightful owner of the land and ordering Andres to vacate the property, reconvey the title to Almuete, and pay attorney's fees. The trial court found that Andres did not acquire any right over the land and that the cancellation of Almuete's award and the issuance of the homestead patent to Andres were fraudulent. The decision became final and executory, and a writ of execution was issued. Andres filed a motion to quash the writ of execution, which the trial court did not act upon, prompting Andres to file a petition for certiorari before the Court of Appeals.

ISSUES:

  1. Whether Marcelo Andres acquired any right over the subject property when he supposedly bought it from Victor Masiglat.

  2. Whether Rodrigo Almuete abandoned the subject property.

  3. Whether the cancellation of Rodrigo Almuete's award and the issuance of the homestead patent in favor of Marcelo Andres were perpetrated through fraud.

RULING:

  1. Marcelo Andres did not acquire any right over the subject property when he supposedly bought it from Victor Masiglat because the latter never acquired ownership from the original owner, Rodrigo Almuete. Marcelo Andres failed to present any valid document to prove his acquisition of the property.

  2. Rodrigo Almuete did not abandon the subject property. The field investigation and inspection report by Leticia Gragasin stating that Rodrigo Almuete had waived his rights to the property due to poor health and financial hardship was found to be obviously false and misleading.

  3. The cancellation of Rodrigo Almuete's award and the issuance of the homestead patent in favor of Marcelo Andres were perpetrated through fraud.

PRINCIPLES:

  • The acquisition of ownership over a property requires a valid transfer or conveyance, supported by written documents.

  • Abandonment of a property requires clear and unequivocal acts of relinquishment or non-use, which were not present in this case.

  • Fraud vitiates all actions, contracts, and transactions.