The document summarizes two court cases from the Philippines regarding land ownership disputes:
1) In Talavera vs. Laxamana, the court ruled that a "Casunduan" document surrendering land rights was not a valid surrender as the farmer, Laxamana, continued working the land and seemed forced to sign without understanding.
2) In Bernas vs. CA, the court ruled that an agreement allowing a farmer, Bernas, to work land in exchange for supporting the landowner's children was binding, as the landowner had legal possession and authority to establish such agreements under the Agricultural Land Reform Code.
The cases address what constitutes valid voluntary surrender of land rights versus binding agricultural
The document summarizes two court cases from the Philippines regarding land ownership disputes:
1) In Talavera vs. Laxamana, the court ruled that a "Casunduan" document surrendering land rights was not a valid surrender as the farmer, Laxamana, continued working the land and seemed forced to sign without understanding.
2) In Bernas vs. CA, the court ruled that an agreement allowing a farmer, Bernas, to work land in exchange for supporting the landowner's children was binding, as the landowner had legal possession and authority to establish such agreements under the Agricultural Land Reform Code.
The cases address what constitutes valid voluntary surrender of land rights versus binding agricultural
The document summarizes two court cases from the Philippines regarding land ownership disputes:
1) In Talavera vs. Laxamana, the court ruled that a "Casunduan" document surrendering land rights was not a valid surrender as the farmer, Laxamana, continued working the land and seemed forced to sign without understanding.
2) In Bernas vs. CA, the court ruled that an agreement allowing a farmer, Bernas, to work land in exchange for supporting the landowner's children was binding, as the landowner had legal possession and authority to establish such agreements under the Agricultural Land Reform Code.
The cases address what constitutes valid voluntary surrender of land rights versus binding agricultural
The document summarizes two court cases from the Philippines regarding land ownership disputes:
1) In Talavera vs. Laxamana, the court ruled that a "Casunduan" document surrendering land rights was not a valid surrender as the farmer, Laxamana, continued working the land and seemed forced to sign without understanding.
2) In Bernas vs. CA, the court ruled that an agreement allowing a farmer, Bernas, to work land in exchange for supporting the landowner's children was binding, as the landowner had legal possession and authority to establish such agreements under the Agricultural Land Reform Code.
The cases address what constitutes valid voluntary surrender of land rights versus binding agricultural
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TALAVERA VS. LAXAMANA (G.R. NO.
77830, FEBRUARY 27, 1990)
FACTS: Jose Laxamana instituted an action for recovery of possession on July 10, 1984 against the petitioners over a parcel of land. He had been in continuous possession of the said land until the petitioners took possession of it and planted palay without private respondents knowledge. Laxamana suffered damages amounting to P500.00, the price equivalent to sixty-five cavans of palay per agricultural year. Petitioners stated that the taking of the private respondents possession was in accordance with their Casunduan executed on March 30, 1973 and that he was not actually a tenant of the petitioners. The document states that private respondent sold his rights and interests over the property for a consideration of P1, 000.00. The RTC ruled in favour of the private respondent to which the petitioners appealed in the Court of Appeals. The Court of Appeals affirmed the lower courts decision that the Casunduan did not constitute valid surrender of the land contemplated under the law. ISSUE: Whether or not there was valid surrender contemplated by the law HELD: No, the surrender did not constitute a valid surrender as contemplated by the law. The Decision of the RTC and the CA is affirmed. Under the Code of Agrarian Reforms of the Philippines (R.A. No. 3844) Section 8, agricultural leasehold shall only be extinguished based on the following grounds: (a) abandonment of the landholding without the knowledge of the agricultural lessor; (b) voluntary surrender of the landholding by the agricultural lessee, written notice of which shall be served three months in advance; or (c) absence of the person under Section nine to succeed to the lessee, in the event of death or permanent incapacity of the lessee. Voluntary surrender does not require any court authorization since it involves the tenants own volition however, it must be shown that the surrender was voluntary through convincing and sufficiently proved evidence. It cannot be presumed nor implied otherwise, the right of the tenant to security of tenure becomes illusory one. It was shown that the Casunduan was prepared by petitioner and that Laxamana needed money for his wifes illness; he could hardly sign his own name; he continued working on the land until 1984 while the Talaveras claimed that they cultivated the land themselves. The circumstances showed that Laxamana was forced to sign the Casunduan without fully understanding it and continued cultivating the land after.
BERNAS VS. CA (G.R. NO. 85041, AUGUST 5, 1993)
FACTS: Private respondent Natividad Bito-on Deita gratuitously entrusted her farm lots by way of dugo to her brother Benigno Bito-on so he would be able to support his childrens schooling in Manila. Benigno then engaged Graciano Bernas in a production sharing agreement wherein Benigno will shoulder the expenses and Bernas will provide labor. Benigno later returned the lots to his sister after his children finished schooling. Natividad not knowing of the agreement, sought to take over possession of the lots but Bernas refused to relinquish, claiming that he was an agricultural leasehold lessee and as such entitled to security of tenure. Regional Trial Court ruled in favour of Bernas stating that he is a leasehold lessee using R.A. 1199 and 3844 (Agricultural Land Reform Code). She appealed to the Court of Appeals on the basis that the agreement between Bernas and Benigno was not binding upon her since she was not aware of it and that her agreement with Benigno was one of commodatum and therefore he cannot lend nor lease the property at hand. CA rule in her favour. ISSUE: Whether or not the agreement between Benigno and Bernas is binding upon Natividad HELD: Yes, it is binding. R.A. 3844 made Benigno the legal possessor, granting him the authority and capacity to institute agricultural leasehold lessees. The code also provides that the leasehold relation shall not be extinguished by mere expiration of the term or period in a leasehold contract nor by the sale, alienation or transfer of the legal possession of the landholding. Natividad did not raise the issue of terminating the leasehold so this court cannot decide on that. The rule is that the Court is properly compelled not to go beyond the issue litigated in the court a quo. Natividad changed the theory of her case from court to court which is not allowed. There was also no evidence that would establish the specifics of her agreement or dugo with her brother.
