The Supreme Court held that a tenant farmer’s right to the land they till is protected against unlawful surrender or transfer, reinforcing the agrarian reform’s goal of empowering landless farmers. This decision underscores the importance of ensuring that any surrender of land rights by a tenant is genuinely voluntary and informed, safeguarding the tenant’s security of tenure and preventing exploitation.

From Farmer to Beneficiary: Can Tenancy Rights Be Surrendered?

This case revolves around Emiliano De Guzman Raymundo, who claimed tenancy over a 1.473-hectare agricultural land in Meycauayan, Bulacan, covered by Original Certificate of Title (OCT) No. 01726. Raymundo asserted that the land was under the Operation Land Transfer (OLT) program of Presidential Decree (P.D.) No. 27, and he was included in the master list of agricultural tenants, leading to the issuance of Certificate of Land Transfer (CLT) No. 0-042717 in 1981. However, the heirs of Patricio Asuncion, the original landowner, sold the land to Philippine Ville Development Housing Corporation (Phil-Ville), which subsequently sold it to Moldex Products Incorporated (Moldex), and portions to Speed Mix, Incorporated. The central legal question is whether Raymundo’s tenancy rights were validly surrendered, thereby justifying the subsequent land transfers.

The petitioners argued that Raymundo’s predecessor-in-interest, his mother Remedios Raymundo, voluntarily surrendered her tenancy rights, and Raymundo himself confirmed this in an affidavit. They claimed this extinguished any rights Raymundo had to the land. The Court, however, was not persuaded, emphasizing the State’s policy to make small farmers independent and self-reliant, as enshrined in Republic Act (R.A.) No. 3844, the Agricultural Land Reform Code. Section 7 of R.A. No. 3844 ensures that tenant-farmers enjoy security of tenure, allowing them to continue working the land until the leasehold relation is extinguished.

Section 8 of R.A. No. 3844 outlines specific grounds for the extinguishment of agricultural leasehold relations, including abandonment, voluntary surrender, and absence of successors. Regarding voluntary surrender, the Court stressed that it must be convincingly and sufficiently proved, as the tenant’s intention to surrender cannot be presumed or implied. The Supreme Court cited Nisnisan v. Court of Appeals, stating that if the intention to surrender is not clear, the tenant farmer’s right to security of tenure becomes illusory.

To protect the tenant’s right to security of tenure, voluntary surrender, as contemplated by law, must be convincingly and sufficiently proved by competent evidence. As held in Nisnisan v. Court of Appeals, the tenant’s intention to surrender the landholding cannot be presumed, much less determined by mere implication. If not, the right of a tenant farmer to security of tenure becomes an illusory one.

The Court emphasized that for a surrender to be considered voluntary, the intention to relinquish the right must be clear and coupled with the physical act of surrendering possession of the farmland. Furthermore, R.A. No. 3844 requires that the voluntary surrender must be due to circumstances more advantageous to the tenant and their family. In this case, the alleged surrender by Remedios Raymundo was deemed ineffective because she was not the recognized tenant; records showed Raymundo was the identified tenant. The Court also found Raymundo’s Sinumpaang Salaysay unconvincing, noting his claim that he was an illiterate who was coaxed into signing a document he did not understand.

The Court gave weight to the fact that Raymundo never left the premises and continued to cultivate the land, eventually being issued a CLT in 1981. This demonstrated that he did not intend to surrender his tenancy rights. Moreover, his dispossession occurred only in 1991 when Speed Mix fenced the area, further underscoring his continued claim to the land. This approach contrasts with a situation where a tenant voluntarily relinquishes possession and seeks alternative means of livelihood, indicating a clear intention to abandon the tenancy.

Turning to the issue of whether Moldex was a buyer in good faith, the Court ruled in the negative. P.D. No. 27 aims to emancipate poor farm families from the bondage of the soil, guaranteeing their continued possession and enjoyment of the land they till. Therefore, agricultural lands covered by P.D. No. 27 must remain in the hands of the tenant-beneficiary. Paragraph 13 of Presidential Decree No. 27 clearly states:

Title to land acquired pursuant to this Decree or the Land Reform Program of the Government shall not be transferable except by hereditary succession or to the Government in accordance with the provisions of this Decree, the Code of Agrarian Reforms and other existing laws and regulations.

Any transfer violating this proscription is null and void, according to Memorandum Circular No. 7, series of 1979. At the time of the sale between the heirs of Asuncion and Phil-Ville, Raymundo already held a CLT, proving his inchoate ownership. The Court affirmed that any individual dealing with agricultural lands covered by P.D. No. 27 must adhere to its provisions. The issuance of the CLT to Raymundo meant he was the rightful owner, and any transfer circumventing the law’s mandate could not be upheld, reinforcing the law’s intent to protect tenant-farmers.

The Court also addressed the Certificate of Non-Tenancy issued by Team Leader Armando Canlas, stating it was of no considerable value. Certifications regarding the presence or absence of a tenancy relationship are considered preliminary and do not bind the Judiciary. The fact that Raymundo was issued a Certificate of Land Transfer diminished the weight of Canlas’ certification. However, the Court modified the DARAB’s decision by deleting the order requiring the generation of an Emancipation Patent in favor of Raymundo. The issuance of an Emancipation Patent requires proof of full payment of amortizations, which was not established in this case. Land transfer under P.D. No. 27 occurs in two phases: the issuance of a CLT and the issuance of an Emancipation Patent upon full payment of annual amortizations.

FAQs

What was the key issue in this case?	The central issue was whether a tenant farmer’s rights to the land were validly surrendered, allowing subsequent land transfers. The Court examined the validity of the surrender of tenancy rights and the implications of Presidential Decree No. 27.
What is a Certificate of Land Transfer (CLT)?	A CLT is a provisional title of ownership issued to a farmer-beneficiary, recognizing their ownership of the land while they are awaiting full payment or are still amortizing owners. It signifies that the land is covered by the Operation Land Transfer program.
What does it mean to voluntarily surrender tenancy rights?	Voluntary surrender means a tenant farmer willingly gives up their rights to the land. The surrender must be clear, intentional, and coupled with the physical act of relinquishing possession, and it must be due to circumstances more advantageous to the tenant and their family.
What is the significance of Presidential Decree (P.D.) No. 27?	P.D. No. 27 aims to emancipate poor farm families from the bondage of the soil, guaranteeing their continued possession and enjoyment of the land they till. It restricts the transfer of agricultural lands covered by the decree except through hereditary succession or to the government.
Can agricultural lands covered by P.D. No. 27 be transferred?	No, agricultural lands covered by P.D. No. 27 cannot be transferred except by hereditary succession or to the government. Any other transfer is considered null and void, as it violates the intent of the law to protect tenant-farmers.
What is an Emancipation Patent?	An Emancipation Patent is the final proof of full ownership of the landholding issued to the farmer-beneficiary upon full payment of the annual amortizations or lease rentals. It represents the completion of the land transfer process under P.D. No. 27.
What role does the Department of Agrarian Reform (DAR) play?	The DAR is responsible for implementing agrarian reform laws, including identifying farmer-beneficiaries, issuing Certificates of Land Transfer, and facilitating the transfer of land ownership. The DAR ensures compliance with agrarian reform policies and protects the rights of tenant farmers.
What happens if a tenant farmer is forced to sign a document surrendering their rights?	If a tenant farmer is forced or coerced into signing a document surrendering their rights, the surrender is not considered voluntary and is therefore invalid. The Court will protect the tenant’s rights and ensure that the surrender was genuinely voluntary and informed.

In conclusion, the Supreme Court’s decision reinforces the protection of tenant farmers’ rights under agrarian reform laws, ensuring that any surrender of land is genuinely voluntary and informed. This ruling serves as a reminder of the importance of upholding the principles of agrarian reform and safeguarding the rights of landless farmers.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: HEIRS OF PATRICIO ASUNCION VS. EMILIANO DE GUZMAN RAYMUNDO, G.R. No. 177903, August 22, 2012