GAVINO CORPUZ,PETITIONER, VS. SPOUSES GERONIMO GROSPE AND HILARIA GROSPE, RESPONDENTS.

Corpuz versus Grospe

The Case

This is the case of Corpuz versus Grospe, decided by the Supreme Court in June 2000. Gavino Corpuz, a farmer-beneficiary under the Operation Land Transfer program of the Department of Agrarian Reform, brought an action for recovery of possession against the spouses Geronimo Grospe and Hilaria Grospe, who had taken over the cultivation of his landholding. The case matters because it draws the line between two things that look alike but are legally opposite: a prohibited private transfer of land reform rights, which is void, and a voluntary surrender of those rights in favor of the government, which is valid. Every agrarian law examination turns on that distinction.

Procedural History

The action for recovery of possession was filed before the Department of Agrarian Reform Adjudication Board in Cabanatuan City, Region Three. The Provincial Agrarian Reform Adjudicator ruled that the petitioner had abandoned and surrendered the landholding to the Samahang Nayon of Malaya, Santo Domingo, Nueva Ecija, which had recommended the reallocation of the lots to the respondent spouses as the most qualified farmer-beneficiaries. The Department of Agrarian Reform Adjudication Board affirmed the provincial adjudicator, and denied the petitioner's motion for reconsideration.

The petitioner then appealed to the Court of Appeals, which dismissed the appeal and affirmed the decision below. The appellate court held that the petitioner had abandoned the landholding and forfeited his rights as a beneficiary, that the waiver of his rights and his conformity to the Samahang Nayon resolutions were evidence of abandonment and voluntary surrender, and that he had failed to prove forgery by clear and convincing evidence. Reconsideration was denied. The petitioner then came to the Supreme Court by a petition for review on certiorari.

Facts

Gavino Corpuz was a farmer-beneficiary under the Operation Land Transfer program. Pursuant to Presidential Decree Number 27, he was issued a Certificate of Land Transfer over two parcels of agricultural land with a total area of three point three hectares in Salungat, Santo Domingo, Nueva Ecija, formerly owned by Florentino Chioco.

To pay for his wife's hospitalization, the petitioner first mortgaged the land in favor of Virginia de Leon. When that contract expired, he mortgaged the land again, this time to respondent Hilaria Grospe, for four years, from December 1986 to December 1990, to guarantee a loan of thirty-two thousand five hundred pesos. The parties executed a contract denominated as a Kasunduan sa Pagpapahiram ng Lupang Sakahan, which allowed the respondents to use or cultivate the land during the mortgage. The respondents later claimed that, instead of paying the loan, the petitioner executed a Waiver of Rights over the landholding in their favor in consideration of fifty-four thousand three hundred ninety-four pesos. The petitioner denied waiving his rights and alleged that his signature and those of his sons on the waiver were forgeries.

In January 1991, the petitioner filed an action for recovery of possession, alleging that the respondents had entered the land by force and intimidation and destroyed the palay he had planted. The provincial adjudicator found that the petitioner had abandoned and surrendered the landholding to the Samahang Nayon, which had recommended that the lots be reallocated to the respondent spouses.

Issues

• Whether or not the appellate court was correct in finding that the signatures of the petitioner and his sons on the Waiver of Rights were not forged.
• Whether or not, assuming the signatures were genuine, the waiver was null and void for being contrary to the agrarian reform laws.
• Whether or not the petitioner abandoned his rights as a beneficiary under Presidential Decree Number 27.
• Whether or not the petitioner, by voluntary surrender, forfeited his right as a beneficiary.

Applicable Provisions

Presidential Decree Number 27, as discussed in the decision, provides:

Title to land acquired pursuant to the land reform program shall not be transferable except through hereditary succession or to the government, in accordance with the provisions of existing laws and regulations.

This is the rule that makes the private waiver void and yet permits the surrender to the government.

Section 8 of Republic Act Number 3844 provides:

The agricultural leasehold relation shall be extinguished by voluntary surrender of the landholding by the agricultural lessee.

This is the provision that allows the tenancy relation to be extinguished by the lessee's own voluntary act.

Memorandum Circular Number 7, Series of 1979, of the then Ministry of Agrarian Reform, quoted in the decision, provides:

Despite the above prohibition, however, there are reports that many farmer-beneficiaries of Presidential Decree Number 27 have transferred the ownership, rights, and or possession of their farms or homelots to other persons or have surrendered the same to their former landowners. All these transactions or surrenders are violative of Presidential Decree Number 27 and therefore, null and void.

This circular confirms that transfers to private persons are void, which is why the waiver in this case could not stand.

Ruling

On the first issue, the Court held that the filing of an information for estafa through falsification does not by itself prove forgery; it only means the public prosecutor found probable cause. Forgery is never presumed and must be proved by clear and convincing evidence, which the petitioner failed to do. The Court respected the factual findings of the agrarian tribunals and the appellate court, which coincided and were supported by the evidence.

On the second issue, the Court ruled that the sale or transfer of rights over property covered by a Certificate of Land Transfer is void, except when the alienation is made in favor of the government or through hereditary succession. The purpose is to prevent a reversion to the old feudal system and to keep the tenant free from the bondage of the soil. The waiver in favor of the respondents, private persons, was therefore void.

On the third issue, the Court ruled that there was no abandonment. Abandonment requires a clear and absolute intention to renounce a right, and an external act carrying that intention into effect. The Court found no such intent, because the mortgage expired after four years and the respondents were obligated to return possession upon full payment of the loan.

On the fourth issue, the Court ruled that the petitioner did voluntarily surrender his landholding to the Samahang Nayon, and that this surrender qualifies as a transfer to the government. The nullity of the waiver did not save him, because the surrender to the Samahang Nayon formed part of the mechanism for the reallocation of farmholdings. Voluntary surrender as a mode of extinguishing the tenancy relation does not require court approval, as long as it is convincingly proved by competent evidence. It was the government, through the Department of Agrarian Reform, that awarded the landholding to the private respondents as qualified beneficiaries.

Doctrine

First, the sale, transfer, or conveyance of land reform rights is, as a rule, void, in order to prevent a circumvention of the agrarian reform laws. Second, the exception is a conveyance in favor of the government, which includes a voluntary surrender or waiver of rights in favor of the Samahang Nayon, because such a surrender is deemed a legally permissible conveyance to the government. Third, after such surrender, the Department of Agrarian Reform validly awards the property to qualified beneficiaries. Fourth, abandonment requires a clear and absolute intention to renounce the right, plus an external act carrying that intention into effect. Fifth, forgery is never presumed and must be proved by clear and convincing evidence.

Disposition

The Supreme Court denied the petition and affirmed the decision and resolution of the Court of Appeals insofar as they dismissed the petitioner's appeal, with costs against the petitioner.

Remember This

The single line to memorize is this: a transfer of land reform rights to a private person is void, but a voluntary surrender of those rights to the government, through the Samahang Nayon, is valid. Examiners use this case to test the exception to the prohibition on alienation of land reform rights, and to test the elements of abandonment.