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  • Vianzon v. Macaraeg

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    Susie Soto
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    This case involves a land dispute between Anita C. Vianzon and Minople Macaraeg over ownership of a 2.5-hectare property. Minople had worked on the land since 1950 as its actual tiller and occupant. In 2004, the Office of the President ruled that the original owner's daughter, Lucila Candelaria Gonzales, was the rightful beneficiary based on an agreement from 1960. However, the Supreme Court overturned this, finding that Minople had tenure rights as he performed all farm work and was paid from harvests, not as a wage worker, and as the actual tiller he was entitled to the land under the Constitution and Agrarian Reform Law. The

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    7. Vianzon v. Macaraeg

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    This case involves a land dispute between Anita C. Vianzon and Minople Macaraeg over ownership of a 2.5-hectare property. Minople had worked on the land since 1950 as its actual tiller and occupant. In 2004, the Office of the President ruled that the original owner's daughter, Lucila Candelaria Gonzales, was the rightful beneficiary based on an agreement from 1960. However, the Supreme Court overturned this, finding that Minople had tenure rights as he performed all farm work and was paid from harvests, not as a wage worker, and as the actual tiller he was entitled to the land under the Constitution and Agrarian Reform Law. The

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as pdf or txt
    305 views3 pages

    Vianzon v. Macaraeg

    Uploaded by

    Susie Soto
    This case involves a land dispute between Anita C. Vianzon and Minople Macaraeg over ownership of a 2.5-hectare property. Minople had worked on the land since 1950 as its actual tiller and occupant. In 2004, the Office of the President ruled that the original owner's daughter, Lucila Candelaria Gonzales, was the rightful beneficiary based on an agreement from 1960. However, the Supreme Court overturned this, finding that Minople had tenure rights as he performed all farm work and was paid from harvests, not as a wage worker, and as the actual tiller he was entitled to the land under the Constitution and Agrarian Reform Law. The

    Copyright:

    © All Rights Reserved
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    of 3

    CASE: ANITA C. VIANZON vs.

    MINOPLE MACARAEG
    G.R. No. 171107. September 5, 2012.

    PONENTE: MENDOZA, J.:

    ISSUE:

    Whether Minople is the rightful beneficiary of the subject land.

    FACTS:

    The subject land is Lot No. 1222 which is part of the divided lot 657.

    The original owner of the lot 657 in Barangay Saguing, Dinalupihan, Bataan is Pedro Candelaria (Pedro). He
    hired Minople to work on the Lot 657 in 1950. In 1956 Pedro then divided the lot into four, one for each children
    and one of which is Lucila Candelaria Gonzales (Lucila). Lucila then executed a deed of absolute sale in favor of
    her daughter, Redenita Vianzon (Redenita), conveying a 2.5-hectare portion of the subject land. Included in the
    agreement is Minople’s signature on a document denominated as “Weiver of Right” (relinguishing all his rights
    over the proper in favor of Redenity. Anita filed two applications to purchase the subject property while Minople,
    filed his own application to purchase the same land. According to the Chief of the Legal Division of the DAR
    Provincial Office recommended: subject land be “divided equally” between the two applicants since both had
    been in some way “remiss in their obligations under the agrarian rules.” The MARO then made its
    recommendation to PARO and subsequently the RD or Regional Director issued an order dividing the property
    based on “in pari delicto, the most equitable solution is to award the property to both of them.”

    Minople appealed to RD and was elevated to the DAR Secretary who upheld Minople’s right over the property
    because he is the “actual possessor/cultivator of the lot in consideration.” in November 10, 1997. Also considered
    was Lucila’s act of “hiring” Minople to render service pertaining to all the aspects of farming violate the old LTA
    Administrative Order (A.O.) but it also contravened the very undertaking made by Lucila’s representative and
    heir, Anita, in her latest sales application warranting its rejection.

    Anita appealed to the Office of the president (OP), who issued a minute decision affirming in toto the November
    10, 1997 that Minople has the right over the property.

    Anita then moved for reconsideration.

    August 18, 2004, the OP, giving weight to the “Agreement to Sell No. 5216” between Lucila and the DAR’s
    predecessor (the LTA), issued a resolution reversing and setting aside its minute decision and declaring Lucila as
    “the legitimate and lawful purchaser/ beneficiary of the landholding in question.”14

    According to OP the subject lot;


    a. had been paid for as early as 1971 and that the same had been declared in the name of the late Lucila for
    tax purposes.
    b. “personal cultivation aspect of the said Agreement to Sell” was achieved or carried out by Lucila “with
    Minople Macaraeg as her hired farmworker.”OP note that neither the LTA nor the DAR failed to give the
    necessary notice of cancellation to Lucila or Anita.

    c. OP opined that when the Agreement to Sell was executed back in 1960, Minople was merely hired as a
    farmworker; ergo, his actual possession and cultivation were not in the concept of owner which explained
    why the LTA (now DAR) contracted with Lucila and not with Minople.17
    RULING:

    1. Minople has a rightful claim to the land because he is its actual tiller and occupant and is therefore entitled
    to the land under the Constitution and R.A. 6657 or the Agrarian Reform Law.

    2. Minople was considered a tenant because he was not hired to work on just a branch of farming and paid a
    fixed wage, but was made to do all farm chores and paid 20 cavans of palay from the produce of every
    harvest.

    Legal basis:
    Constitution, more particularly Articles II and XIII:

    Article II
    SEC. 21. The State shall promote comprehensive rural development and agrarian reform.
    SEC. 4. The State shall, by law, undertake an agrarian reform program founded on the right of farmers and
    farm workers, who are landless, to own directly or collectively the lands they till or, in the case of other
    farmworkers, to receive a just share of the fruits thereof.

    Congress enacted R.A. No. 6657, or the CARL of 1988. Section 22 of this law enumerates those who should
    benefit from the CARL.

    SEC. 22. Qualified Beneficiaries.—The lands covered by the CARP shall be distributed as much as possible
    to landless residents of the same barangay, or in the absence thereof, landless residents of the same
    municipality in the following order of priority:
    (a) agricultural lessees and share tenants;
    (b) regular farmworkers;
    (c) seasonal farmworkers;
    (d) other farmworkers;
    (e) actual tillers or occupants of public lands;
    (f) collectives or cooperatives of the above beneficiaries; and
    (g) others directly working on the land.

    A basic qualification of a beneficiary shall be his willingness, aptitude and ability to cultivate and make the land
    as productive as possible . The DAR shall adopt a system of monitoring the record or performance of each
    beneficiary, so that any beneficiary guilty of negligence or misuse of the land or any support extended to him
    shall forfeit his right to continue as beneficiary. The DAR shall submit periodic reports on the performance of the
    beneficiaries to the PARC.

    A.O. No. 3, Series of 1990. The foremost policy in said A.O.’s Statement of Policies states, Land has a social
    function, hence, there is a concomitant social responsibility in its ownership and should, therefore, be distributed
    to the actual tillers/occupants, who is Menople.

    A.O. No. 3 lays down the qualifications of a beneficiary in landed estates26 in this wise: he or she should be
    (1) landless;
    (2) Filipino citizen;
    (3) actual occupant/tiller who is at least 15 years of age or head of the family at the time of filing of
    application; and
    (4) has the willingness, ability and aptitude to cultivate and make the land productive.
    The act of Lucila Candelaria Gonzales in allowing Minople Macaraeg to perform all the farming activities in the
    subject lot established a tenancy relationship between the former and the latter because the latter is doing the farm
    chores and is paid from the produce or harvest of the land in the amount of 20 cavans of palay every harvest. The
    claim of Lucila Candelaria Gonzales that Minople Macaraeg is only a hired farm worker will not hold water,
    considering the fact that he (Minople Macaraeg) was not hired to work on just a branch of farming, but performed
    work pertaining to all the branches thereof, on the basis of sharing the harvest not on a fixed salary wage.38

    R.A. No. 6657 or the CARL “is a social justice and poverty alleviation program which seeks to empower the lives
    of agrarian reform beneficiaries through equitable distribution and ownership of the land based on the principle
    of land to the tiller.40

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