Talavera vs Laxamana

Facts:
An action for recovery of possession was instituted by the private respondent against the petitioners over
a parcel of agricultural land. Laxamana had been the bonafide tenant of the said parcel of agricultural land
until the Talaveras took possession of it. LAxamana had the continuous possession and cultivation of the
said land until the Talaveras planted palay through after LAxamana plowed and harrowed the said land.
Laxamana suffered damages due to this. The Talaveras countered Laxamanas statement saying that their
tenancy relationship was terminated by an agreement, and through this, Laxamana has already sold his
rights and interests over the said land. They also alleged that Laxamanas allegations were baseless.
Consequently, Laxamana was favoured by the Court but it was reversed by the Appellate Court.
Issue:
Whether or not by virtue of the agreement, Laxamana as tenant is deemed to have surrendered voluntarily
the subject landholding to its owners.
Held:
Court held that the evidence on record and the petitioners' arguments are not enough to overcome the
rights of the private respondent provided in the Constitution and agrarian statutes which have been upheld
by this Court. The very essence of agricultural tenancy lies in the cardinal rule that an agricultural tenant
enjoys security of tenurial status. The Code of Agrarian Reforms of the Philippines (Republic Act No.
3844, as amended) specifically enumerates the grounds for the extinguishment of agricultural leasehold
relations. Voluntary surrender does not require any court authorization but it must be sufficiently proved
by evidence in order to be used as a protection for right of security of tenure for tenants. The tenant's
intention to surrender the landholding cannot be presumed, much less determined by mere implication.
The agreement made by them contained voluntary relinquishment of tenancy. The argument of the private
respondent that under Section 28 of the Agrarian Reform Code, a voluntary surrender to be valid must be
"due to circumstances more advantageous to him and his family" is double-edged. Laxamana even
resided in the same location as the disputed land but the Talaveras lived in another barangay, it cannot
overcome the more convincing evidence of persons actually residing where the land is located. Tenancy
relations cannot be bargained away except for the strong reasons provided by law which must be
convincingly shown by evidence in line with the State's policy of achieving a dignified existence for the
small farmers free from pernicious institutional restraints and practices

CENTRAL MINDANAO UNIVERSITY VS. DARAB

Facts:
On 16 January 1958, President Carlos Garcia issued Proclamation No. 467 reserving for the Mindanao
Agricultural College, now the CMU, a piece of land to be used as its future campus. In 1984, CMU
embarked on a project titled "Kilusang Sariling Sikap" wherein parcels of land were leased to its faculty
members and employees. Under the terms of the program, CMU will assist faculty members and
employee groups through the extension of technical know-how, training and other kinds of assistance. In
turn, they paid the CMU a service fee for use of the land. The agreement explicitly provided that there
will

be

no

tenancy

relationship

between

the

lessees

and

the

CMU.

When the program was terminated, a case was filed by the participants of the "Kilusang Sariling Sikap"
for declaration of status as tenants under the CARP. In its resolution, DARAB, ordered, among others, the
segregation of 400 hectares of the land for distribution under CARP. The land was subjected to coverage
on the basis of DAR's determination that the lands do not meet the condition for exemption, that is, it is
not "actually, directly, and exclusively used" for educational purposes.
Issue:
Is the CMU land covered by CARP? Who determines whether lands reserved for public use by
presidential proclamation is no longer actually, directly and exclusively used and necessary for the
purpose for which they are reserved?
Held:
The land is exempted from CARP. CMU is in the best position to resolve and answer the question of
when and what lands are found necessary for its use. The Court also chided the DARAB for resolving this
issue of exemption on the basis of "CMU's present needs." The Court stated that the DARAB decision
stating that for the land to be exempt it must be "presently, actively exploited and utilized by the
university in carrying out its present educational program with its present student population and
academic faculty" overlooked the very significant factor of growth of the university in the years to come.

Pagtalunan

vs.

Tamayo

G.R. 54281, March 19, 1990

Facts:
On January 17, 1978, the Republic of the Philippines filed a complaint with the Court of First Instance of
Bulacan for expropriation of a parcel of land located in Bo. Tikay, Malolos, Bulacan, owned by private
respondents, and on March 2 of the same year, the said court issued a writ of possession placing the
Republic in possession of the land. The petitioners, Celso and Paulina Pagtalunan, filed a supplemental
motion for leave to intervene, with a complaint in intervention attached, alleging that petitioner Celso
Pagtalunan has been the bona fide agricultural tenant of a portion of the land. Petitioners asked the trial
court to order payment to Celso Pagtalunan of just compensation for his landholding or, in the alternative,
to order payment of his disturbance compensation as bona fide tenant. Respondent, Judge Roque A.
Tamayo, issued an order denying the petitioners' supplemental motion, holding that to admit petitioners'
complaint in intervention would be tantamount to allowing a person to sue the State without its consent
since the claim for disturbance compensation is a claim against the State.
Issues:
1. Whether or not the petitioners have the right to intervene in the expropriation proceedings instituted by
the

State

against

private

respondents

as

registered

owner

of

the

subject

property.

2. Whether or not the Court of Agrarian Reforms has original and exclusive jurisdiction over
expropriation proceedings for public purpose of all kinds of tenanted properties.
Held:
1. The Court ruled in the negative. It held that the mere issuance of the certificate of land transfer does not
vest in the farmer/grantee ownership of the land described therein. The certificate simply evidences the
government's recognition of the grantee as the party qualified to avail of the statutory mechanisms for the
acquisition of ownership of the land tilled by him as provided under Pres. Decree No. 27. Neither is this
recognition permanent nor irrevocable. It is the emancipation patent which constitutes conclusive
authority for the issuance of an Original Certificate of Transfer, or a Transfer Certificate of Title, in the
name

of

the

grantee.

The petitioners herein have not been issued an emancipation patent and have not even complied with the
conditions enumerated in their certificate of land transfer which would entitle them to a patent,
2. The Court found no reason to dwell on this point. The issue of what court has jurisdiction over the
expropriation proceedings in this case was rendered moot and academic by B.P. Blg. 129. Under
Paragraph 7, Section 19 of B.P. Blg. 129, all civil actions and special proceedings which were then under

the exclusive jurisdiction of the Court of Agrarian Relations were placed under the exclusive and original
jurisdiction of the Regional Trial Courts [formerly the Courts of First Instance].