- Petitioner
- Filinvest Land
- Respondent
- Eduardo R. Adia
- Citation
- G.R. No. 192629
- Court
- Supreme Court
- Division
- Second Division
- Decided
- November 25, 2015
Summary
This case involves 75 farmer-beneficiaries who received land awards under the Comprehensive Agrarian Reform Law (CARL) but executed affidavits transferring their rights to Filinvest Land, Inc. in 1995. The farmers claimed they understood this was for a joint venture to develop a residential subdivision, but when no development occurred and Filinvest fenced the properties, they filed an action for recovery of possession. The Supreme Court ruled that the affidavits violated Section 27 of CARL, which prohibits transfer of awarded lands within 10 years, making the transfers void. Applying the Article 1416 Civil Code exception to the pari delicto doctrine, the Court allowed the farmers to recover their lands since the prohibition was designed to protect them and public policy favors agrarian reform. The decision affirms that waivers of rights over agrarian reform lands are void and that farmer-beneficiaries retain the right to recover such lands despite having received compensation.