In Levardo v. Yatco, the Supreme Court affirmed that landowners are not mandated to transfer ownership of land to tenant farmers if their landholdings are seven hectares or less. Additionally, the Court upheld the validity of waivers signed by tenant farmers who voluntarily surrendered their land rights in exchange for disturbance compensation, provided such waivers were made with a clear understanding of the circumstances and were not vitiated by fraud or coercion. This decision reinforces the importance of adhering to legal frameworks governing agrarian reform and recognizing agreements made in good faith between landowners and tenant farmers.

Can a Landowner Reclaim Property after Tenant’s Waiver in Land Reform Cases?

This case involves two consolidated petitions concerning land located in Biñan, Laguna. In DARAB Case No. 3361, the petitioners, heirs of Aguido Levardo, claimed that their father was a tenant of Asuncion Belizario, who later donated the land to Tomas Yatco. Aguido allegedly waived his tenancy rights for compensation. In DARAB Case No. 3362, Hernando Levardo and his father, Francisco, claimed tenancy on land owned by Leoncio Yatco, with Hernando also executing a waiver for compensation. Both sets of petitioners sought to nullify the waivers and subsequent sales of the properties to Gonzalo Puyat and Sons, Inc., arguing that the lands were covered by Presidential Decree No. 27 (P.D. No. 27), which mandates the transfer of land ownership to tenant farmers.

The Provincial Agrarian Reform Adjudicator (PARO) initially ruled in favor of the petitioners, declaring the waivers and deeds of sale as null and void, and ordering the issuance of Emancipation Patents. However, upon reconsideration, the PARO reversed its decision, upholding the validity of the waivers and deeds of sale. The Department of Agrarian Reform Adjudication Board (DARAB) initially reversed the PARO’s reconsidered decision but later reinstated the PARO’s order, which was affirmed by the Court of Appeals (CA). The central legal question is whether the lands in dispute fall under the coverage of P.D. No. 27 and whether the waivers of tenancy rights executed by the petitioners’ predecessors are valid.

The Supreme Court affirmed the CA’s decision, emphasizing that P.D. No. 27, when read in conjunction with Letter of Instruction No. 474 (LOI No. 474) and the DAR Memorandum, explicitly excludes landholdings of seven hectares or less from its coverage. Since both disputed lands were less than seven hectares, they did not fall under P.D. No. 27. LOI No. 474 specifies that even smaller landholdings might be covered if the landowner possesses other agricultural lands exceeding seven hectares or derives sufficient income from other properties. However, the Court noted that the petitioners failed to provide evidence demonstrating that the landowners owned other properties meeting these criteria.

Building on this principle, the Court addressed the validity of the waivers executed by the petitioners’ predecessors. Section 28 of Republic Act No. 3844 allows agricultural lessees to terminate leasehold agreements through voluntary surrender if it is more advantageous for them and their families. The Court found that the disturbance compensation received by Aguido and Hernando Levardo demonstrated such advantage, as it allowed them to pursue other livelihoods.

Section 28. Termination of Leasehold by Agricultural Lessee During Agricultural Year –
The agricultural lessee may terminate the leasehold during the agricultural year for any of the following causes: (5) Voluntary surrender due to circumstances more advantageous to him and his family.

Furthermore, the Court highlighted the fact that these waivers were notarized, thus carrying a presumption of regularity, which the petitioners failed to overcome with sufficient evidence. In effect, by affixing their signatures on these documents and benefiting from the financial compensation offered, petitioners effectively relinquished any claim to rights associated with the properties.

Regarding the Certificates of Land Transfer (CLTs), the Court clarified that a CLT does not automatically vest ownership in the farmer. Instead, it merely recognizes the grantee’s qualification to acquire ownership, subject to the mechanisms provided in P.D. No. 27. Because the disputed lands were outside the scope of P.D. No. 27, any CLTs allegedly issued were deemed without legal basis. The court acknowledged the petitioners’ arguments claiming they signed the document unwarily, believing they would become the landowners. However, considering the amount of money involved, there’s reason to believe they agreed to sign in exchange for monetary compensation as presented in court.

The Supreme Court ultimately ruled in favor of the landowners and the corporation that purchased the lands. This decision underscores the importance of complying with agrarian reform laws while also respecting agreements made in good faith between landowners and tenant farmers. It reinforces the principle that social justice should not disregard the rights of landowners. It reiterates a commitment to fairness, balancing the need to protect landless farmers while also protecting the rights of landowners from baseless claims.

FAQs

What was the central issue in this case?	The main issue was whether the lands in dispute were covered by Presidential Decree No. 27, mandating land transfer to tenant farmers, and the validity of tenancy rights waivers.
What is Presidential Decree No. 27?	P.D. No. 27 is a decree that aims to emancipate tenant farmers from the bondage of the soil by transferring land ownership to them. It applies primarily to rice and corn lands.
Did the lands in question fall under P.D. No. 27?	No, the lands in question did not fall under P.D. No. 27 because they were less than seven hectares, and the landowners did not own other significant properties.
What is a Certificate of Land Transfer (CLT)?	A CLT is a document recognizing a farmer’s qualification to acquire land ownership under P.D. No. 27. It doesn’t automatically grant ownership.
Were CLTs actually issued in this case?	The Court found no reliable evidence that valid CLTs were issued to the petitioners or their predecessors.
What is a waiver of tenancy rights?	A waiver of tenancy rights is a voluntary relinquishment of a tenant’s right to cultivate and own land, often in exchange for compensation.
Were the waivers of tenancy rights valid in this case?	Yes, the Court upheld the validity of the waivers because they were notarized, and the tenants received substantial disturbance compensation.
What happens to the land after a valid waiver is executed?	After a valid waiver, the landowner is free to sell or develop the land, as the tenant’s claim to the land has been legally relinquished.
What is disturbance compensation?	Disturbance compensation is a payment made to a tenant farmer as a consideration for surrendering their tenancy rights, usually to assist them in finding alternative means of livelihood.

This case underscores the complexities of agrarian reform in the Philippines. While P.D. No. 27 aims to protect landless farmers, it also recognizes the rights of landowners and the validity of agreements made in good faith. As the Philippines continues to navigate its agrarian reform policies, this decision serves as a reminder of the need for balance and fairness in the application of the law.

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: Levardo v. Yatco, G.R. No. 165494, March 20, 2009