Benjamin v. Guiang

Summary

This landmark case established that the 1973 Constitution's 24-hectare limit on land acquisition amended the Public Land Act's 144-hectare limit, applying to all lands originally acquired from public domain even after becoming private property. The Supreme Court declared void a compromise agreement for transfer of 146 hectares of such lands, particularly since the transferees already owned 29 hectares. The Court applied Civil Code provisions on void contracts, ruling that agreements contrary to constitutional public policy cannot be ratified and allowing recovery under Article 1416 when the prohibition protects the transferor and enhances public policy. The decision ordered reconveyance of previously transferred lots and treated all payments as damages rather than purchase consideration, establishing important precedent on constitutional limits in land transactions and the non-ratifiability of void agreements.