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FACTS: Juan Griño, Sr. (GRINO), now deceased, owned two properties: (1) a 9.

35 hectare agricultural land, and (2) a


50 hectare parcel of land both located in Iloilo which he, on February 8, 1972, mortgaged to DBP as security for a loan.
The agricultural land was placed under the coverage of PD 27 because it is a tenanted Riceland. Certificates of Land
Transfer (CLTs) were issued in favor of his tenants.

Later, Grino filed a letter-petition to cancel the CLTs contending that he was deprived the opportunity to be heard and
the Riceland only covered 6 hectares of the property. In line with the property covered by the CLTs, he offered 7 hectares
from the said 50-hectare land. However, said property was later dationed to DBP to settle the loan. GRINO died in 1985
before the COMPREHENSIVE AGRARIAN REFORM LAW (CARL) took effect. In 1989, DAR Regional Director
Antonio S. Maraya acted on GRINO’s petition for cancellation and dismissed the same.

In 1997, the heirs of GRINO sought exemption of the 9.35 hectare land from the coverage of either PD27 and CARL,
claiming that the 7 children-heirs were entitled to 5 hectares each pursuant to Sec 6 of the CARL. Grino had seven
children and if a landowner is entitled to 5 hectares as retention limit, the remaining land of Griño would not be enough
for his children, the 50-hectare land of Grino having already been ceded to the DBP. However, in 1998, the DAR
Regional Director Dominador Andres dismissed the application for retention, declaring that the reckoning date of the
OLT was in October 21, 1972 and not date of effectivity of the CARL (June 15, 1988).

The heirs appealed to the DAR Secretary. However, he further declared since GRINO, pursuant to LOI 474, “was not
entitled to exercise his retention right over subject property under PD 27. As such, he is also not entitled to exercise
said right under RA 6657. If Juan Griño, Sr. had no retention rights under PD 27 and RA 6657, it follows that his heirs,
who are his successors-in-interest, cannot also exercise the same right under PD 27 and RA 6657.”

On further appeal, the CA upheld the decision of the DAR Secretary, further holding that res judicata and laches had
already set in. The heirs filed a motion for reconsideration claiming that they were not able to participate in the petition
for cancellation of CLTs and as such they should not be bound by the decisions of DAR Regional Director. This motion
was denied.
Hence the present petition.

ISSUE/S: W/N the heirs may resurrect the retention issue?

HELD: NO. The DAR was the agency vested by law with the authority to rule on retention issues and its ruling lapsed
to finality 15 days after its service. The ruling has been duly served and has reached finality appear to us to be
uncontroverted. The DAR ruling is a ruling on the merits of Juan Griño, Sr.’s petition for cancellation of the issued
CLTs, and laid to rest any issue of retention as between Juan Griño, Sr. and his successors, and the government. Thus,
res judicata fully applies.

According to the SC, the heirs were guilty of laches in their attempt to “resurrect the retention issue seven
and a half years after its denial was decreed and came to finality.”

Allowing the heirs to resurrect the long entombed issue of retention under the circumstances of this
case would not only be a major setback for the government’s agrarian reform program, but would be
unjust as well to the individual tenants-beneficiaries who are now full pledged owners of the lands they
till. The DAR cannot be faulted if no substitution of parties took place when Griño died, it being the duty of the
heirs to attend to the estate of the deceased, which duty includes notification to adjudicating tribunals the fact
of death of the litigant.

DOCTRINE: Allowing the heirs to resurrect the long entombed issue of retention under the circumstances of this
case would not only be a major setback for the government’s agrarian reform program, but would be unjust as well to
the individual tenants-beneficiaries who are now full pledged owners of the lands they till. The heirs have a duty to
attend to the estate of the deceased.