SAMAHANG MAGSASAKA NG 53 EKTARAYA v.

MOSQUERA
RPI | March 22 2007 | J. Velasco

SUMMARY: Petitioner alleges that the sale to the respondents of the disputed land without DAR clearance is in violation
of the Comprehensive Agrarian Reform Law. Respondents then filed for an exemption which was ultimately granted by the
OP. On appeal to CA and the SC, it was found that petitioners are not the RPIs and does not have standing to file the suit.

DOCTRINE:

FACTS OF THE CASE:

Parties Petitioner: Samahang Magsasaka ng 53 Hektarya
Respondent: Wilfredo Mosquera, Rosario Roman, Danilo Relucio, Edgardo Vergara

 Petitioner is an association of farmer-beneficiaries accredited by the DAR.

o Alleged that its members have been cultivating the land for many years prior to the effectivity of the CARL.
 Respondents are the registered owner of the disputed lands in Macabud, Rodriguez, Rizal.
o The land was previously owned by the Philippine Suburban Development Corporation. It was then sold in
1979 to Vinebel Realties through an extrajudicial foreclosure sale.
 PET argues that in 1994, the land was sold to RESP without DAR clearance.
 The Municipal Agrarian Reform Officer (MARO) of Rodriguez issued a Notice of Coverage over the disputed land.

PROCEDURAL HISTORY:
● RESP filed for an exemption to the CARL because the land was allegedly above
Regional Director of the 18% slope and unfit for cultivation.
DAR o The Regional Director of DAR-Region IV denied the respondents’
application and MR.

DAR Secretary  DAR Secretary denied the appeal of RESP.

Office of the  RESP filed an appeal with the OP which subsequently granted the same.
President o PET filed an MR with the OP but it was denied.

● PET appealed the decision of the OP to the CA through Rule 43.

o CA denied the appeal because it found that the petitioner was not a real
Court of Appeals party-in-interest and thus, had no legal standing to sue.
o It cited Fortich v. Corona and ruled that because the PET was only a
beneficiary, not the actual grantee, of the land, it has no standing to sue.

Supreme Court  Petition Denied

ISSUES & RATIO:

1. Whether PET are the real parties-in-interest - NO

 According to Sec. 2 Rule 3 of the RoC, a real party-in-interest is a party who stands to be benefited or injured by
the judgment in a suit or the party entitled to the avails of the suit.
o Fortich v. Corona: Farmer-beneficiaries, who are not approved awardees of CARP, are not RPIs.
 APPLICATION: Members of the PET are mere qualified beneficiaries of CARP
o The certification that CLOAs were already generated in their names, but were not issued because of the
present dispute, does not vest any right to the farmers since the fact remains that they have not yet been
approved as awardees, actually awarded lands, or granted CLOAs.
 While the Court sometimes disregards the rules of procedure in the interest of justice, we find that the present case
does not merit such leniency.
o The requirement that a party must have real interest in the case is essential in the administration of justice.
Thus, having resolved that the respondents have no legal standing to sue and are not the real parties-in-
interest, we find no more necessity to take up the other issues.

DISPOSITIVE: WHEREFORE, the petition is DENIED