Scribd
Upload
153 views2 pages

Agrarian Dispute: Dalit vs. Balagtas

Vivencio Dalit filed a petition before the PARAD against the Balagtas family and others claiming rights as a tenant farmer over a disputed lot of land. Dalit alleged he had been tilling the land and giving portions of harvest proceeds to the Balagtas family head. However, the Balagtas family later mortgaged the land without Dalit's consent. The land was eventually distributed under the Comprehensive Agrarian Reform Program, with Dalit receiving a Certificate of Land Ownership Award for a portion, confirming his right to possess that portion of the disputed land. The court held that Dalit's right of possession arises from the CLOA issued to him under the agrarian reform program.

Uploaded by

Rob
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
153 views2 pages

Agrarian Dispute: Dalit vs. Balagtas

Vivencio Dalit filed a petition before the PARAD against the Balagtas family and others claiming rights as a tenant farmer over a disputed lot of land. Dalit alleged he had been tilling the land and giving portions of harvest proceeds to the Balagtas family head. However, the Balagtas family later mortgaged the land without Dalit's consent. The land was eventually distributed under the Comprehensive Agrarian Reform Program, with Dalit receiving a Certificate of Land Ownership Award for a portion, confirming his right to possess that portion of the disputed land. The court held that Dalit's right of possession arises from the CLOA issued to him under the agrarian reform program.

Uploaded by

Rob
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd

G.R. No.

202799, March 27, 2019

VIVENCIO DALIT, PETITIONER, v. SPOUSES ROLANDO E. BALAGTAS, SR. AND


CARMELITA G. BALAGTAS, ROLANDO G. BALAGTAS, JR., CLARINA G. BALAGTAS,
CARLOTA G. BALAGTAS, CARMELA G. BALAGTAS, SOFRONIO SARIENTE * AND
METROPOLITAN BANK AND TRUST COMPANY, RESPONDENTS.

Facts: Dalit filed before the Office of the Provincial Agrarian Reform Adjudicator (PARAD)
a  petition for maintenance of possession, with prayer for issuance of status quo order and/or
injunction10 (PARAD petition) against the Balagtas family and respondents Sofronio Sariente
and Metropolitan Bank and Trust Company, Inc. (Metrobank).

Dalit averred that Rolando, Sr., with the consent of the rest of the Balagtas family, instituted him
as tenant farmer of the Disputed Lot, and that he had been tilling it since then. Dalit further
alleged that he had been remitting a portion of the proceeds of the harvest to Balagtas, Sr. as
part of the tenurial arrangement.

Dalit alleged that the Balagtas family later mortgaged the Disputed Lot in favor of Metrobank
without his consent, in order to secure an P8,000,000.00 loan.15 The Balagtas family defaulted,
leading to the foreclosure of the mortgage constituted over the Disputed Lot and the
consolidation of title in Metrobank's name.16 Subsequently, the Balagtas family directed Dalit to
vacate the Disputed Lot.

Rolando, Sr. denied that Dalit had been instituted as tenant farmer of the Disputed Lot, and
claimed that he was merely employed as bulldozer and street roller operator during the
construction of a memorial park constituted thereon. Further, Rolando, Sr. assailed the PARAD's
jurisdiction, claiming that the Disputed Lot had already been classified as residential property,
as stated in Tax Declaration issued in favor of the Balagtas family.

To bolster his claim, Dalit presented a certified true copy of the actual tax declaration covering
the Disputed Lot which indicates that it is still classified as rice land. He claims that supervening
events have rendered moot respondents' claim over the Disputed Lot, particularly the division
and subsequent distribution of the Disputed Lot through the issuance of Certificates of Land
Ownership Award (CLOAs) in favor of several agrarian reform beneficiaries (ARBs) chosen by
the Department of Agrarian Reform (DAR), one of whom is Dalit.

Issue: Whether that Dalit had establish his status as a de jure tenant of the Disputed Lot.

Held: Dalit's right of possession arises from CLOA.

The CARP covers not only alienable and disposable lands of the public domain, but also those
lands owned by the government in its private capacity and lands owned by private
individuals, provided they are devoted to or suitable for agriculture.

The fact that the Disputed Lot is agricultural in nature is clearly established by the evidence on
record. To recall, Tax Declaration No. 02927, presented by the Balagtas family to show that the
Disputed Lot had already been re-classified for residential use, was shown to have been forged
through OCA-Cabanatuan's Certification, which states: “This is to certify that the Tax
Declaration issued in the name of Rolando L. Balagtas should be considered null and void,
because of its nature as being made under bad faith.”

Further, one of the modes by which DAR implements the distribution of agricultural lands under
the CARP is through the issuance of a CLOA. A CLOA is a document evidencing ownership of
the land granted or awarded to the qualified ARB, and contains the restrictions and conditions of
such grant. The issuance of CLOA No. T-2165 in Dalit's favor thus confirms his right to retain
possession over the portion of the Disputed Lot identified thereunder, such possession being an
attribute of ownership granted in his favor.

You might also like