Land Titles and Deeds Case Digests annabee
Top Management Programs Corp. v. Luis Fajardo and the Register of Deeds of Las Pi ñas
City | GR 150462 | June 15, 2011 | J. Villarama, Jr.
FACTS: Emilio Gregorio filed an application for registration of title over Lots 1 to 4 of Plan Psu-
204785 situated at Mag-asawang Mangga, Las Piñas, Rizal, before the then Court of First Instance
of Rizal; said court issued an order declaring as abandoned the reserved oppositions of Jose T.
Velasquez and Pablo Velasquez.
Meanwhile, Jose T. Velasquez filed an application for registration of title over six lots before the
same court. The CFI rendered a decision declaring Gregorio to be the absolute owner of Lots 1, 2,
3 and 4 described in Plan Psu-204785. On March 9, 1966, an order was issued by said court for
the issuance of the decree of registration.
The LRA called the attention of the Director of Lands regarding the overlapping of several lots
awarded to Velasquez, with lots adjudicated to Gregorio, and requested that portions of these lots
that are not in conflict be segregated. LRA informed the CFI that Lots 1 and 7 had been amended
by the Bureau of Lands to exclude therefrom portions covered by Lot 2, Psu-64894, Psu-96904,
and Lots 1 to 4, Psu-204785 of Gregorio. Velasquez petitioned the CFI to set aside the award
earlier made in favor of Gregorio. The CFI issued an Order declaring that the application of
Velasquez be given due course insofar as Lots 1 and 7 of Ap-11135 which are identical to Lots 1 to
4, Plan Psu-204785 in favor of Gregorio respecting the same lots as null and void. Certificates of
Title were issued in favor of Velasquez. Gregorio appealed the decision of the CFI to the CA.
Sometime after this, he entered into an agreement with Tomas Trinidad (Trinidad) and Luis Fajardo
(Fajardo) entitled “Kasunduan na may Pambihirang Kapangyarihan. ” By virtue of this agreement,
Fajardo would finance the cost of the litigation and in return he would be entitled to one-half of the
subject property after deducting twenty per cent (20%) of the total land area as attorney’s fees for
Trinidad if the appeal is successful. Fajardo and Trinidad filed Civil Case before the RTC of Pasig
to enforce their agreement with Gregorio. The court rendered judgment in their favour.
Meanwhile, herein petitioner Top Management Programs Corporation sought the annulment of the
CFI orders on the ground of extrinsic fraud. Petitioner claimed that by virtue of a notarized Deed of
Absolute Sale, the heirs of Gregorio sold to it a parcel of land and a TCT covering the said property
was issued in its name. The CA rendered its decision dismissing the petition for annulment.
ISSUE: W/N Petitioner may quiet title and order the cancellation of the TCT in favor of Luis
Fajardo.
HELD: No. In an action for quieting of title, the plaintiffs must show not only that there is a cloud or
contrary interest over the subject real property, but that they have a valid title to it. The court is
tasked to determine the respective rights of the complainant and the other claimants, not only to
place things in their proper places, and to make the claimant, who has no rights to said immovable,
1
respect and not disturb the one so entitled, but also for the benefit of both, so that whoever has the
right will see every cloud of doubt over the property dissipated, and he can thereafter fearlessly
introduce the improvements he may desire, as well as use, and even abuse the property as he
deems fit.
The TCT in the name of the heirs of Emilio Gregorio, on its face showed badges of irregularity in its
issuance. First, the technical description. Second, the decree number and date of issuance, as
well as OCT number clearly indicate that the original decree pertained to Velasquez and not
Gregorio. Third, the name of the registered owner in the original certificate is not Velasquez or
Gregorio but “Delta Motor Corp.” And fourth, the certificate from which TCT No. 107729 was
supposedly a transfer should have been the OCT (of Gregorio) and not those unfamiliar TCT
numbers indicated therein.
There are serious discrepancies in the registration process. In fact, it is not far-fetched that the
erroneous entries could have been intended to create the impression that TCT No. 107729 was a
separate and distinct title from the previously issued TCT No. S-91911 even if they pertain to one and
the same lot adjudicated to Emilio Gregorio. Such conclusion is reinforced by the unexplained
inaction or failure of the heirs of Gregorio to rectify the alleged errors in their title before selling the
property to petitioner. The heirs of Gregorio knew that their TCT bore encumbrances in favor of third
parties, notably the notice of pending litigation ( Lis Pendens) involving the property covered by said
title before the CFI of Pasig, Metro Manila in Civil Case, which Trinidad caused to be annotated
thereon. The issuance of a new certificate with exactly identical entries would mean that the aforesaid
annotations had to be carried over to such new certificate.
Petitioner being a mere transferee at the time the decision of the RTC of Pasig in Civil Case had
become final and executory, it is bound by the said judgment which ordered the heirs of Emilio
Gregorio to convey the lots in favor of private respondent and Trinidad. As such buyer of one of
the lots to be conveyed to private respondent pursuant to the court’s decree with notice that said
properties are in litigation, petitioner merely stepped into the shoes of its vendors who lost in the
case. Such vested right acquired by the private respondent under the final judgment in his favor
may not be defeated by the subsequent issuance of another certificate of title to the heirs of
Gregorio respecting the same parcel of land. For it is well-settled that being an involuntary
transaction, entry of the notice of lis pendens in the primary entry book of the Register of Deeds is
sufficient to constitute registration and such entry is notice to all persons of such claim.
Manotok Realty v. Tecson | GR L-47475 | August 19, 1988 | J. Gutierrez, Jr.
FACTS: In a complaint filed by the petitioner for recovery of possession against defendants, Court
of First Instance of Manila ruled declaring respondent Nilo Madlangawa a builder in good faith. The
Court of Appeals affirmed and the Supreme Court dismissed for lack of merit.

The petitioner filed with the trial court, presided over by respondent Judge Tecson, a motion for the
approval of petitioner's exercise of option and for satisfaction of judgment, praying that the court
issue an order: a) approving the exercise of petitioner's option to appropriate the improvements
introduced by the private respondent on the property; b) thereafter, private respondent be ordered
to deliver possession of the property in question to the petitioner.
However, since there is a pending case involving the expropriation of the land in question it is
better to suspend the current case until after the outcome of the expropriation proceedings is done.
After a denial of its motion for reconsideration, the petitioner filed the present petition for
mandamus alleging that the respondent judge committed grave abuse of discretion. Moreover, a
fire engulfed the Tambunting estate covering the disputed area of the land. The expropriation case
was not granted and the law that provided for such was declared unconstitutional. The petitioner is
contending that the execution of the decision must now involve the delivery of possession due to
the fire.
ISSUE: Whether or not the execution of the decision must now involve the delivery of possession
by the respondent to the petitioner due to the fire
HELD: Yes. When the decision of the trial court became final and executory, it becomes incumbent
upon the respondent judge to issue the necessary writ for the execution of the same. There is,
therefore, no basis for the respondent judge to deny the petitioner's motion to avail of its option to
appropriate the improvements made on its property. Settled is the rule that after a judgment has
become final, no additions can be made thereto, and nothing can be done therewith except its
execution, otherwise there would be no end to legal processes.
The repairs and improvements introduced by the said respondents after the complaint was filed
cannot be considered to have been built in good faith, much less, justify the denial of the
petitioner's option. Since the improvements have been gutted by fire, and therefore, the basis for
private respondent's right to retain the premises has already been extinguished without the fault of
the petitioner, there is no other recourse for the private respondent but to vacate the premises and
deliver the same to herein petitioner.
Heirs of Labanon v. Heirs of Labanon | GR 160711 | August 14, 2004 | J. Velasco, Jr.
FACTS: Constancio Labanon settled upon a piece of alienable and disposable public agricultural
land situated in Kidapawan, Cotabato. He cultivated the said lot and introduced permanent
improvements. Constancio asked his brother, Maximo, who was better educated to file a public
land application under the express agreement that they will divide the said lot as soon as it would
be feasible for them to do so. During the time of the application it was Constancio who continued to
cultivate the said lot. The Homestead Application was approved and an Original Certificate of Title
over said lot was issued in favor of Maximo Labanon.
2
Land Titles and Deeds Case Digests annabee
Maximo Labanon executed a document denominated as “Assignment of Rights and Ownership” to
safeguard the ownership and interest of his brother Constancio Labanon. Later on, Maximo
executed a sworn statement reiterating his desire that his elder brother Constancio, his heirs and
assigns shall own the eastern portion of the Lot.
After the death of Constancio, his heirs executed an [e]xtra-judicial settlement of estate with
simultaneous sale over the aforesaid eastern portion of the lot in favor of Alberto Makilang, the
husband of Visitacion Labanon, one of the children of Constancio. Subsequently, the parcel of land
was declared for taxation purposes in the name of Alberto. The defendants heirs of Maximo
caused to be cancelled from the records of the defendant Provincial Assessor of Cotabato the
aforesaid tax declaration and the latter, without first verifying the legality of the basis for said
cancellation, cancelled the same. The heirs of Constancio demanded the owner’s copy of the
certificate of title covering the aforesaid Lot to be surrendered to the Register of Deeds.
ISSUES:
1. W/N the OCT issued the name of MAXIMO LABANON be now considered
indefeasible and conclusive; and
2. W/N the Trust Agreement allegedly made by Constancio Labanon and Maximo
Labanon prescribed
HELD:
1. No. Section 32 of PD 1529 does not totally deprive a party of any remedy to recover the
property fraudulently registered in the name of another. It merely precludes the reopening of
the registration proceedings for titles covered by the Torrens System, but does not foreclose
other remedies for the reconveyance of the property to its rightful owner. While it is true that
Section 32 of PD 1529 provides that the decree of registration becomes incontrovertible after a
year, it does not altogether deprive an aggrieved party of a remedy in law. The acceptability of
the Torrens System would be impaired, if it is utilized to perpetuate fraud against the real
owners. The action for Recovery of Ownership before the RTC is indeed the appropriate
remedy.
2. No. Maximo Labanon maintained the title over the property while acknowledging the true
ownership of Constancio Labanon over the eastern portion of the land. The existence of an
express trust cannot be doubted nor disputed. In the case at bar, Maximo never repudiated the
express trust instituted between him and Constancio. And after Maximo’s death, the trust could
no longer be renounced; thus, respondents’ right to enforce the trust agreement can no longer
be restricted nor prejudiced by prescription. In addition, petitioners can no longer question the
validity of the positive declaration of Maximo Labanon in the Assignment of Rights and
Ownership in favor of the late Constancio Labanon, as the agreement was not impugned during
the former’s lifetime and the recognition of his brother’s rights over the eastern portion of the lot
was further affirmed and confirmed in the subsequent Sworn Statement.
 Land Titles and Deeds Case Digests annabee

Republic v. Santua | GR 155703 | September 8, 2008 | J. Nachura

Paz v. DENR, PEA, and Filinvest | GR 157367 | November 23, 2011 | J. Bersamin
FACTS: Dominador Santua filed with the RTC of Calapan a petition for judicial reconstitution of
FACTS: Petitioner Luciano Paz brought a petition for the cancellation of OCT, he averred that he Transfer Certificate of Title (TCT). Respondent alleged that he is the registered owner of certain
was the owner of a parcels of land situated in Parañaque City, Pasay City, Taguig City and San parcels of land situated in Poblacion, Victoria however the original copy of the TCT was destroyed
Pedro, Laguna, Alabang, Muntinlupa, Parañaque City and Las Piñas City; and that such OCT was by the fire that completely razed the Capitol Building then housing the Office of the Register of
registered in the name of the Republic, that Filinvest developed one of the lots into a subdivision Deeds. The owner's duplicate copy was lost while in respondent's possession. The respondent and
based on their joint venture agreement with the Government; that lot was further subdivided, his family are in actual possession of the property and have been paying taxes thereon; and there
causing the cancellation of TCT and the issuance of TCTs for the resulting individual subdivision are no deeds affecting the property. Attached to the petition were a tax declaration, survey plan,
lots in the names of the Republic and Filinvest; and that the subdivision lots were then sold to third and technical description of each lot.
parties.
The RTC issued an Order setting the initial hearing of the case, notifying all adjoining owners
Filinvest moved to dismiss the petition for cancellation contending that the serious and mentioned in the petition and no one interposed any objection thereto. The original and the owner's
controversial dispute spawned by the Petition for cancellation of title is litigable in an ordinary duplicate copies of the TCT were reconstituted in the name of Dominador Santua. The Solicitor
action outside the special and limited jurisdiction of land registration courts. The petitioner General opposed, filing a Notice of Appeal.
countered that his petition for cancellation was not an initiatory pleading that must comply with the
regular rules of civil procedure but a mere incident of a past registration proceeding; that unlike in ISSUE: W/N tax declarations, survey plans, and technical descriptions are sufficient bases for the
an ordinary action, land registration was not commenced by complaint or petition, and did not reconstitution of lost or destroyed certificates of title.
require summons to bring the persons of the respondents within the jurisdiction of the trial court;
and that a service of the petition sufficed to bring the respondents within the jurisdiction of the trial HELD: No. A tax declaration is not a reliable source for the reconstitution of a certificate of title. At
court. The RTC ruled in favor of Filinvest which was reversed by the CA. most, the tax declaration can only be prima facie evidence of possession or a claim of ownership,
which however is not the issue in a reconstitution proceeding. A reconstitution of title does not pass
ISSUE: Whether or not the petitioner can reconvey the property in question in favor of him upon the ownership of the land covered by the lost or destroyed title but merely determines
whether a reissuance of such title is proper.
HELD: No. The filing of the petition would have the effect of reopening the decree of registration,
and could thereby impair the rights of innocent purchasers in good faith and for value. To reopen As for the survey plans and technical descriptions, the Court has previously dismissed the same as
the decree of registration was no longer permissible, considering that the one-year period to do so not the documents referred to in Section 3(f) but merely additional documents that should
had long ago lapsed, and the properties covered by OCT had already been subdivided into smaller accompany the petition for the reconstitution as required by law. Moreover, a survey plan or
lots whose ownership had passed to third persons. Thusly, the petition tended to violate the technical description prepared at the instance of a party cannot be considered in his favor, the
proviso in Section 108 of P.D. No. 1529, to wit: same being self-serving.

xxx Provided, however, That this section shall not be construed to give the court authority to
reopen the judgment or decree of registration, and that nothing shall be done or ordered by the RECONSTITUTION OF A CERTIFICATE OF TITLE denotes RESTORATION in the original form
court which shall impair the title or other interest of a purchaser holding a certificate for value in and condition of a lost or destroyed instrument attesting the title of a person to the piece of land. It
good faith, or his heirs and assigns without his or their written consent. Where the owner’s partakes of a land registration proceeding. Thus, it must be granted upon clear proof that the titles
duplicate certificate is not presented, a similar petition may be filed as provided in the preceding sought to be restored was indeed issued to the petitioner. In this regards, Section 3 of RA 26
section. enumerates the documents regarded as valid and sufficient bases for reconstitution of a transfer
certificate of title.
Nor is it subject to dispute that the petition was not a mere continuation of a previous registration
proceeding. The Petition for Review on Certiorari is denied.
Manotok v. Barque | GR 162335 & 162605 | March 6, 2012 | J. Villarama, Jr.

3

FACTS: The surviving heirs of the late Homer Barque, filed a petition with the LRA for
administrative reconstitution of the original copy of TCT No. 210177 issued in the name of Homer
L. Barque, which was destroyed in the fire that gutted the Quezon City Hall, including the Office of
the Register of Deeds of Quezon City, sometime in 1988. In support of the petition, petitioners
submitted the owner’s duplicate copy of TCT No. 210177, real estate tax receipts, tax decla-rations
and the Plan FLS 3168 D covering the property.
The Manotoks filed their opposition to the Barques’ petition, claiming that the lot covered by the title
sought to be reconstituted by the latter forms part of the land covered by the former’s own
reconstituted title, TCT No. RT-22481, and alleging that TCT No. 210177 in the name of Homer L.
Barque is spurious.
The reconstitution was denied on grounds that the two lots covered by the Barques’ title appear to
duplicate the lot covered by the Manotoks’ own reconstituted title; and that the Barques’ plan, Fls-
3168-D, is a spurious document.
On appeal, the LRA reversed the reconstituting officer and ordered that reconstitution of the
Barques’ title be given due course, but only after the Manotoks’ own title has been cancelled upon
order of a court of competent jurisdiction. The CA ordered the Register of Deeds to cancel the
Manotoks’ title. The latter filed these petitions to the SC.
ISSUE: Who is the legal owner of the Piedad Estate in Quezon City?
HELD: The national government of The Repulic of the Philippines is the legal owner of the subject
property. The Supreme Court denied with finality all the motions for reconsideration filed by all
parties in this case. A valid certificate of sale issued to Severino the official document denominated
as “Sale Certificate” clearly required both the signatures of the Director of Lands who issued such
sale certificate to an applicant settler/occupant and the Secretary of the Interior/Agriculture and
Natural Resources indicating his approval of the sale. These forms had been prepared and issued
by the Chief of the Bureau of Public Lands under the supervision of the Secretary of the Interior,
consistent with Act No. 1120. Manotok’s assignors cannot simply be presumed from the execution
of assignment documents in his favor. Neither can it be deduced from the alleged issuance of the
half-torn TCT, itself a doubtful document as its authenticity was not established, much less the
veracity of its recitals because the name of the registered owner and date of issuance do not
appear at all. No Register of Deeds had testified and attested to the fact that the original of TCT
No. 22813 was not under his/her custody, nor that said certificate of title in the name of Severino
Manotok existed in the files of the Registry of Deeds of Caloocan or Quezon City.
The claim of the Barques who, just like the Manahans, were unable to produce an authentic and
genuine sale certificate, must likewise fail. The Decision discussed extensively the findings of the
CA that the Barques’ documentary evidence were either spurious or irregularly procured, which
4
Land Titles and Deeds Case Digests annabee
even buttressed the earlier findings mentioned in the December 18, 2008 Resolution.
On the other hand, the belatedly submitted copy of Sale Certificate No. 511 by the Manahans was
not among those official documents which the Office of the Solicitor General (OSG) offered as
evidence, as in fact no copy thereof can be found in the records of either the DENR-NCR or LMB.
Moreover, the sudden emergence of this unauthenticated document is suspicious, considering that
Celzo who testified, as witness for both the OSG and the Manahans, categorically admitted that
she never actually saw the application to purchase and alleged Sale Certificate No. 511 of the
Manahans.
Repulic v. Tuastumban | GR 173210 | April 24, 2009 | J. Tinga
FACTS: The respondents filed a petition for reconstitution of the OCT covering a lot in Talisay-
Minglanilla Estate in the name of the Legal Heirs of Sofia Lazo. Respondent claims she bought the
property from the said owners who are also her relatives, as evidenced by an Extrajudicial
Declaration of Heirs with Waiver of Inheritance Rights and Deed of Absolute Sale . She claims that
since the time of purchase, she has been occupying and possessing the land and paying the realty
taxes thereon. The OCT which was in the possession of the Register of Deeds of
the Province of Cebu was allegedly either lost or destroyed during World War II. The RTC found the
petition to be sufficient in form and substance and set the hearing of the petition, notifying all
adjoining owners. The petition was not opposed by anyone. Thus, the Register of Deed of Cebu
ordered to reconstitute the lost OCT in the name of the Legal Heirs of Sofia Lazo, the Republic
through the Solicitor General opposed.
ISSUE: Whether the documents presented by respondent constitute sufficient basis for the
reconstitution of title
HELD: No. the following must be present for an order for reconstitution to issue: (a) that the
certificate of title had been lost or destroyed; (b) that the documents presented by petitioner are
sufficient and proper to warrant reconstitution of the lost or destroyed certificate of title; (c) that the
petitioner is the registered owner of the property or had an interest therein; (d) that the certificate of
title was in force at the time it was lost and destroyed; and (e) that the description, area and
boundaries of the property are substantially the same as those contained in the lost or destroyed
certificate of title.
The respondent merely relied on the CENRO certification which is however not the authenticated
copy of the decree of registration or patent required by law. The certification plainly states only that
the lot is patented in the name of the Legal Heirs of Sofia Lazo. It is not even a copy of the decree
of registration or patent itself but a mere certification of the issuance of such patent. Also, she has
not established the issuance or existence of the certificate of title covering the subject lot nor of the

other documents that would prove the existence, execution and contents of the certificate of title
sought to be reconstituted.
The fact that no opposition is filed by a private party or by the Republic of the Philippines will not
relieve respondent, as petitioner in the petition for reconstitution, of his burden of proving not only
the loss or destruction of the title sought to be reconstituted but also that at the time the said title
was lost or destroyed, he or his predecessor-in–interest was the registered owner thereof. The
Republic is not estopped from assailing the decision granting the petition if, on the basis of the law
and the evidence on record, such petition has no merit.
Hacienda Luisita, Inc. v. Secretary of Agrarian Reform | GR 171101 | April 24, 2012 | J.
Velasco, Jr.
FACTS: In the July 5, 2011 Decision, the Court denied the petition for review filed by HLI and
affirmed the assailed Presidential Agrarian Reform Council (PARC) Resolutions with the
modification that the original 6,296 qualified farmworker-beneficiaries of Hacienda Luisita (FWBs)
shall have the option to remain as stockholders of HLI.
Upon separate motions of the parties for reconsideration, the Court, by Resolution of November 22,
2011, recalled and set aside the option thus granted to the original FWBs to remain as stockholders
of HLI, while maintaining that all the benefits and homelots received by all the FWBs shall be
respected with no obligation to refund or return them.
Hacienda Luisita and the Central Azucarera de Tarlac were sold by the Spanish owners of
Tabacalera to Tadeco. The Central Bank of the Philippines assisted Tadeco in obtaining a dollar
loan from a US bank. Also, the GSIS extended them a loan. The martial law administration filed a
suit before the Manila RTC against Tadeco, et al., for them to surrender Hacienda Luisita to the
then Ministry of Agrarian Reform (MAR) so that the land can be distributed to farmers at cost.
Tadeco alleged that Hacienda Luisita does not have tenants and not covered by existing agrarian
reform legislations. The Manila RTC rendered judgment ordering Tadeco to surrender Hacienda
Luisita to the MAR.
During the administration of President Corazon Cojuangco Aquino, the Office of the Solicitor
General moved to withdraw the government’s case against Tadeco, et al. Tadeco organized a spin-
off corporation (HLI) as vehicle to facilitate stock acquisition by the farmworkers. Tadeco conveyed
to HLI the agricultural land portion and other farm-related properties of Hacienda Luisita in
exchange for HLI shares of stock.
5
Land Titles and Deeds Case Digests annabee
Some of the then farmworker-beneficiaries (FWBs) complement of Hacienda Luisita signified in a
referendum their acceptance of the proposed HLI’s Stock Distribution Option Plan (SODP). The
SDOA was formally entered into by Tadeco, HLI, and qualified FWBs. This attested to by then DAR
Secretary Philip Juico.
HLI applied for the conversion of 500 hectares of land of the hacienda from agricultural to industrial
use, which was approved by the DAR. In exchange for subscription of 12,000,000 shares of stocks
of Centennary, ceded 300 hectares of the converted area to the latter. Subsequently, Centennary
sold the entire 300 hectares to Luisita Industrial Park Corporation (LIPCO), which used it in
developing an industrial complex. It was resolved that the subject lands be forthwith placed under
the compulsory coverage or mandated land acquisition scheme of the CARP.
ISSUES:
1. W/N just compensation for the homelots be given to the FWBs
2. W/N the qualified FWBs have control over the agricultural lands
HELD:
1. The issue on just compensation and the grounds HLI and Mallari, et al. rely upon in support
of their respective stance on the matter had been previously raised by them in their first
motion for reconsideration and fully passed upon by the Court in its November 22, 2011
Resolution. Considering that the issue on just compensation has already been passed upon
and denied by the Court in its November 22, 2011 Resolution, a subsequent motion touching
on the same issue undeniably partakes of a second motion for reconsideration, hence, a
prohibited pleading. However, if such issue is again entertained by the Court, the end goal of
equitably distributing ownership of land is, therefore, undeniable. And since it is only upon the
approval of the SDP that the agricultural lands actually came under CARP coverage, such
approval operates and takes the place of a notice of coverage ordinarily issued under
compulsory acquisition. Moreover, precisely because due regard is given to the rights of
landowners to just compensation, the law on stock distribution option acknowledges that
landowners can require payment for the shares of stock corresponding to the value of the
agricultural lands in relation to the outstanding capital stock of the corporation.
2. Yes. The Court agrees that the option given to the qualified FWBs whether to remain as
stockholders of HLI or opt for land distribution is neither iniquitous nor prejudicial to the
FWBs. Nonetheless, the Court is not unmindful of the policy on agrarian reform that control
over the agricultural land must always be in the hands of the farmers. Contrary to the stance
of HLI, both the Constitution and RA 6657 intended the farmers, individually or collectively, to
have control over the agricultural lands of HLI; otherwise, all these rhetoric about agrarian
reform will be rendered for naught. The agrarian reform program is founded on the right of
farmers and regular farm workers, who are landless, to own directly or collectively the lands
they till or, in the case of other farm workers, to receive a share of the fruits thereof, as stated
in the Constitution.
 Land Titles and Deeds Case Digests annabee