a collections of case digests and laws that can help aspiring law students to become a lawyer
Case Digest: Polo Plantation Agrarian Reform Multipurpose Cooperative vs Inson, G.R. No. 189162, January 30, 2019
Polo Plantation Agrarian Reform Multipurpose Cooperative v. Inson
G.R. No. 189162, January 30, 2019
PONENTE: Justice Mario Victor F. Leonen
Sometime in 2003, a parcel of land owned by Polo Coconut Plantation, Inc. (Polo Coconut) in Tanjay, Negros Oriental was placed under the coverage of the Comprehensive Agrarian Reform Program, pursuant to Republic Act No. 6657 or the Comprehensive Agrarian Reform Law. A Notice of Coverage was sent to Polo Coconut.
Meanwhile, the Department of Agrarian Reform (DAR) received from the Land Bank of the Philippines (LBP) a Memorandum of Valuation, indicating the amount of P85,491,784.60 as just compensation for the Polo Coconut property. A Notice of Land Valuation and Acquisition was then sent to Polo Coconut. Subsequently, a Certificate of Deposit was issued to Polo Coconut for the said amount.
After Polo Coconut failed to reply to the Notice of Land Valuation and Acquisition, the DAR, after it conducted summary administrative proceedings to determine just compensation, affirmed the valuation offered by LBP in the amount of P85,491,784.60.
Meanwhile, Polo Coconut’s title was canceled. Thus, a collective Certificate of Land Ownership Award, with CLOA No. 00114438, was issued and was registered under Transfer Certificate of Title (TCT) No. T-802, in favor of POPARMUCO members whom the Department of Agrarian Reform identified as agrarian reform beneficiaries.
Polo Coconut filed before the Court of Appeals (CA) a Petition for Certiorari questioning the propriety of subjecting its property to the Comprehensive Agrarian Reform Program assailing, among others, the eligibility of the identified agrarian reform beneficiaries.
The CA ruled in favor of Polo Coconut. It held that the identified beneficiaries were not qualified as beneficiaries, as they were not tenants of Polo Coconut.
When appealed to the Supreme Court (SC), in its September 3, 2008 Decision, in Department of Agrarian Reform v. Polo Coconut Plantation Company, Inc. (586 Phil. 69) it reversed the CA Decision. It declared the issuance of TCT No. T-802 and CLOA No. 00114438 as valid. The Court further recognized the DAR as the proper authority to identify and select agrarian reform beneficiaries.
The September 3, 2008 Decision became final and executory on November 26, 2008.
Seven (7) months later, on June 30, 2009, Alcantara, et al. filed the Petition for Inclusion/Exclusion. They questioned the inclusion of POPARMUCO’s members as beneficiaries and recipients of Certificates of Land Ownership Award. They alleged that the beneficiaries are not qualified under Section 22 of the Comprehensive Agrarian Reform Law.
On July 1, 2009, Alcantara, et al. also filed a Petition for Immediate Issuance of a Cease and Desist Order and/or Injunction. Thus, they sought a Cease and Desist Order to preserve their legal rights while the administrative proceedings for the inclusion/exclusion of farmer beneficiaries were pending resolution.
Acting on the Petition, Regional Director Inson issued a Cease and Desist Order directing the Certificate of Land Ownership Award holders to CEASE and DESIST from entering or taking possession of the property pending final determination of the inclusion-exclusion proceedings.
POPARMUCO members, who are Certificate of Land Ownership Award holders, filed a Motion to Quash the Cease and Desist Order. They alleged that the Cease and Desist Order defied the Supreme Court’s September 3, 2008 Decision.
POPARMUCO also filed before the Supreme Court a Petition for Contempt against Regional Director Inson, praying that a restraining order or writ of preliminary injunction be issued, directing him to cease: (1) from enforcing the Cease and Desist Order in light of the Petition; and (2) from reviewing the beneficiaries, as the SC had decided with finality on the issue. It further prayed that this Court hold Regional Director Inson guilty of contempt of court.
A. Whether or not Alcantara et. al. may question the validity of the collective Certificate of Land Ownership Award with CLOA No. 00114438 issued to POPARMUCO.
B. Whether or not Director Inson’s cognizance of the Petition for Inclusion/Exclusion of farmer beneficiaries, and his subsequent issuance of the Cease and Desist Order constitute contempt of court.
A. No. The September 3, 2008 Decision had already become final and executory. The finality of this Decision meant that:
Nothing is more settled in law than that a judgment, once it attains finality, becomes immutable and unalterable, and can no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by the highest court of the land. This rule rests on the principle that all litigation must come to an end, however unjust the result of error may appear; otherwise, litigation will become even more intolerable than the wrong or injustice it is designed to correct [Land Bank of the Philippines v. Suntay, 678 Phil. 879, 908-909 (2011)].
In Estribillo v. Department of Agrarian Reform [526 Phil. 700 (2006)], the Court held that certificates of title issued pursuant to emancipation patents are as indefeasible as transfer certificates of title issued in registration proceedings. Further, it ruled that the transfer certificates of title issued to the petitioners became indefeasible upon the expiration of one (1) year from the issuance of the emancipation patents.
Here, by the time the Petition for Inclusion/Exclusion was filed on June 30, 2009, the September 3, 2008 Decision declaring the validity of CLOA No. 00114438 had attained finality and TCT No. T-802 had already become incontrovertible. As registered property owners, POPARMUCO’s members were entitled to the protection given to every Torrens title holder. Their rights may only be forfeited in case of violations of agrarian laws, as well as noncompliance with the restrictions and conditions under the Comprehensive Agrarian Reform Law.
B. Regional Director Inson’s cognizance of the Petition for Inclusion/Exclusion does not constitute defiance of the September 3, 2008 Decision.
In Rivulet Agro-Industrial Corporation v. Paruñgao [701 Phil. 444 (2013)], the SC explained the concept of contempt of court:
Contempt of court is defined as a disobedience to the court by acting in opposition to its authority, justice, and dignity, and signifies not only a willful disregard of the court’s order, hut such conduct which tends to bring the authority of the court and the administration of law into disrepute or, in some manner, to impede the due administration of justice. To be considered contemptuous, an act must be clearly contrary to or prohibited by the order of the court. Thus, a person cannot be punished for contempt for disobedience of an order of the Court, unless the act which is forbidden or required to be done is clearly and exactly defined, so that there can be no reasonable doubt or uncertainty as to what specific act or thing is forbidden or required.
Here, Regional Director Inson justified his cognizance of the Petition for Inclusion/Exclusion based on the Department’s exclusive prerogative in the identification, selection, and subsequent re-evaluation of agrarian reform beneficiaries.
However, as earlier stated, the issue on the qualification of the existing Certificate of Land Ownership Award holders had long been laid to rest in this Court’s final and executory September 3, 2008 Decision.
Still, Regional Director Inson’s erroneous cognizance of the Petition for Inclusion/Exclusion can only be deemed as grave abuse of discretion, which is more properly the subject of a petition for certiorari, not a petition for contempt.
At any rate, whether Regional Director Inson’s actions were improper is not an issue here. What is crucial in contempt proceedings is the intent of the alleged contemnor to disobey or defy the court as held in St. Louis University, Inc. v. Olairez [730 Phil. 444 (2014)]:
In contempt, the intent goes to the gravamen of the offense. Thus, the good faith or lack of it, of the alleged contemnor is considered. Where the act complained of is ambiguous or does not clearly show on its face that it is contempt, and is one which, if the party is acting in good faith, is within his rights, the presence or absence of a contumacious intent is, in some instances, held to be determinative of its character. . . . To constitute contempt, the act must be done willfully and for an illegitimate or improper purpose.
There is no clear and contumacious conduct on the part of Regional Director Inson. His acts do not qualify as a willful disobedience to this Court nor a willful disregard of its authority.
Leave a Reply.