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Tenant Rights in Property Sales

The Mataas na Lupa Tenants' Association filed a case seeking to annul the sale of land owned by Juliana Diego Vda. de Gabriel to Carlos Dimayuga without providing prior notice to the tenant farmers. The court ruled the sale was illegal and invalid because it did not satisfy the conditions established by law to protect the rights of tenants when land is sold. Specifically, the land was not first offered to the petitioners nor did they renounce their rights, as required. The court also emphasized that under the Constitution, private property is held in trust for the people and should benefit the entire community. Therefore, the court set aside the lower court's order and directed that the petitioners' rights be administered

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Eddie Abrenica
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103 views1 page

Tenant Rights in Property Sales

The Mataas na Lupa Tenants' Association filed a case seeking to annul the sale of land owned by Juliana Diego Vda. de Gabriel to Carlos Dimayuga without providing prior notice to the tenant farmers. The court ruled the sale was illegal and invalid because it did not satisfy the conditions established by law to protect the rights of tenants when land is sold. Specifically, the land was not first offered to the petitioners nor did they renounce their rights, as required. The court also emphasized that under the Constitution, private property is held in trust for the people and should benefit the entire community. Therefore, the court set aside the lower court's order and directed that the petitioners' rights be administered

Uploaded by

Eddie Abrenica
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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ABRENICA, Eddie, Jr. S.

/ Obligations and Contracts March 19, 2023

Mataas na Lupa Tenants’ Association v. Carlos Dimayuga and Juliana Diego Vda.
de Gabriel
(G.R. No. L-32049, Jun. 25, 1984)

Facts:
The Mataas na Lupa Tenants' Association filed a case against Juliana Diego Vda. de
Gabriel and Carlos Dimayuga, seeking to annul the deed of sale between the defendants.
The land, owned by respondent Juliana Diez Vda. de Gabriel, had been leased to
petitioners, who had been paying rent until May 14, 1968, when it was sold to respondent
Carlos Dimayuga without prior notice to the tenants. The plaintiffs claimed that the land
sold was a tenanted property, and the defendants had no right to sell the land without the
consent of the co-tenants. They argued that since the aforesaid contract of sale is
expressly prohibited by law, the same be declared null and void and for Vda.

Issue:
Whether or not the contract of sale is null and void.

Ruling:
Yes. The court has determined that the sale of the land to the respondent was conducted
illegally and is therefore invalid. This finding was reached as the conditions established
by R.A. 1162, as amended by R.A. 2342 and 3516, were not satisfied during the sale
process. Specifically, the offering of the land to the petitioners and their renunciation of it
in a public instrument, as required by law, were not met before the land was sold to the
respondent. The court has also emphasized the stewardship concept enshrined in section
6, article II of the 1973 Constitution. This provision posits that private property should be
held by individuals solely as trustees for the people in general, who are the true owners
of the property. As mere stewards, individuals must exercise their right to the property not
for their exclusive benefit, but for the benefit of the entire community.

In light of these findings, the court has set aside the CFI order and directed the Ministry
of Human Settlements to facilitate and administer the implementation of the petitioners'
rights. The cost will be borne by the respondents.

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