THE TENANTS OF THE ESTATE OF DR. JOSE SISON, vs. CA, G.R. No.

93045, June 29, 1992

FACTS:

According to an examination conducted by the Ministry of Agrarian Reform, the late Dr. Sison's estates
were partitioned among his children using an Extra-Judicial Partition document. According on this, it was
suggested that the tenants' certificates of land transfer be revoked. The tenants had received Land
Transfer Certificates for their individual areas of agriculture. Dr. Sison's heirs appealed for their
landholdings to be exempted from the Operation Land Transfer (OLT) on the grounds that they were too
tiny (not more than 7 hectares each). A second Thorough investigation report suggested the move, and
a third report said it should be done. In 1988, then-Secretary Juico declared that certain heirs' ricelands
were free from Organic Land Transfer (OLT), but heirs with fields larger than 7 hectares were not eligible
for either retention or exemption. The tenants of Dr. Sison's estate petitioned the Court of Appeals for
certiorari, which was denied.

ISSUE AND RULING:

If Dr. Sison's heirs are ineligible to keep their agricultural holdings the estate's lands.

No, the heirs are not barred from exercising their respective retention rights.

The heirs' omission to petition for retention of seven (7) hectares of each of their agricultural
landholdings did not establish an estoppel or renunciation of their individual retention rights. The
deficiency was remedied by a timely objection against the issue of land transfer certificates to the
petitioners. Secretary Juico correctly ordered the revocation of the Certificates of Land Transfer that had
been granted to tenants of Dr. Sison's estate in in error. The Secretary's administrative jurisdiction as the
implementor of P.D. extends to the issue, recall, or cancellation of certificates of land transfer. 27. In this
case, it was determined Guernsey that some successors of Dr. Sison were legally entitled to maintain
their ricelands (which did not exceed seven [7] hectares) and had been wrongfully denied that right.