Anita Vianzon vs. Minople Macaraeg

G.R. No. 171107, September 5, 2012

(Comprehensive Agrarian Reform Law, Tenancy)

This case reiterates the basic principle that private ownership of land has limitations, for it comes with the social responsibility to make use of the land according to its productive capacity.

FACTS

The heir of the late Lucila Candelaria Gonzales, Anita C. Vianzon, and Minople Macaraeg are fighting over who can buy Lot No. 1222 from the government. Anita claimed Minople could not own the land because he was merely a hired farmworker therein by Lucila's father. Minople, on the other hand, said he has the right over the land under the Argrarian Reform Law, having worked there as a tenant, farming and sharing in its harvest.

ISSUES

1.) Who between Anita and Minople has a rightful claim to the land?

2.) Was Minople a mere hired farm worker, as Anita claimed, or a tenant entitled to the benefits of the agrarian reform law, as Minople claimed?

RULING

1.) Minople has a rightful claim to the land because he is its actual tiller and occupant and is therefore entitled to the land under the Constitution and R.A. 6657 or the Agrarian Reform Law.

2.) Minople was considered a tenant because he was not hired to work on just a branch of farming and paid a fixed wage, but was made to do all farm chores and paid 20 cavans of palay from the produce of every harvest.

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