CIVIL PROCEDURE Both Melecio and Malines are not qualified beneficiaries under P.D.

27 because they should be identified by the government, or that

DIGAN v MALINES
GR No. 183004 | 6 December 2017
Subtopic: S. Post-judgment remedies; 2. Appeals; f. Review
of judgments or final orders of quasi-judicial agencies
DOCTRINE: The SC has the power to review and reverse findings
of the lower courts if the latter’s factual findings are in conflict
with those of the appellate court, or where there is a
misapprehension of facts.
they are the heirs of the landowner to entitle them for retention,
but instead they acquired the same through sale.
The Petitioner’s admission that the Respondents are farmer-
beneficiaries are conclusive against them, and may be contradicted
only upon showing that it was made through palpable mistake.
Herein, the Petitioners failed to contradict their admission.
Hence, as farmer beneficiaries, the sale of the subject lands to the
Respondents is valid.

FACTS:
 Paris is the owner of 3 parcels of land in Ilocos Sur with
an area of 31.89 hectares with respective TCTs.
 The subject lots were placed under OLT pursuant to P.D.
27, and were divided into 6 lots, and the Petitioners
were qualified as beneficiaries.
 By virtue of a Joitn Affidavit of Waiver, the Petitioner
consented to the sale by Paris of the one of the lots to
Malines and Melecio who were issued a new TCT.
 Unknown to Respondents, the TCT was cancelled by the
RD of Ilocos Sur; while Emancipation Patents were
issued to the Petitioner and registered with the RD.
 Respondents filed a petition for cancellation of the EPs
at the PARAD. Petitioners admitted that the no CLT
were issued to them prior to the issuance of the EPs,
and that Respondents. The PA dismissed the petition.
 The Respondents moved for reconsideration, and the
case was redocketed, but for failure to appear on
hearing, the case was dismissed. Hence, only Malines
appealed to the DARAB.
 While the case was pending on the DARAB, Malines filed
a Petition for Cancellation of the EPs in the PARAD. The
PA disqualified the Petitioners as beneficiaries.
 On appeal, the DARAB dismissed the petition for
cancellation of the EPs.
 The CA reversed the DARAB ruling, and reinstated that
of the PARAD’s.

ISSUE: Whether or not the CA committed a reversible error in not

finding that the PARAD and the DARAB misapprehended the facts.

RULING: Yes. After reviewing the records, the SC found that the
Provincial Adjudicator, the DARAB, and the CA misapprehended an
admitted fact crucial to the resolution of this case.

The records show that the Petitioners executed a Joint Affidavit of

Waiver and abandoned whatever right they may have on the
subject lands. This is sufficient ground for the cancellation of the
EPs registered in their names.

The CA erroneously held that the OLT coverage violated Malines’

right of retention considering that the subject land was below her
retention limit.