G.R. No. 163026 HEIRS OF CASTRO v. LOZADA 679 SCRA 271

HEIRS OF CASTRO v. LOZADA
G.R. NO. 163026

August 29, 2012

FACTS: Respondents are the occupants/tillers of a rice land (Lot 546) and recognized Arcadio Castro, Sr. as their landlord. They filed applications to purchase the said lot. However, records showed that the registered claimant is one "Arcadio Cruz."

Consequently, the Land Inspector issued a clearance of sale to the tenants. However, the application was stalled by Arcadio Castro, Sr. who contended that through his sister-in-law, they were paying the “cost and rental” of the lot for he owns it.

In 1990, upon findings that “Arcadio Cruz” and Aracadio Castro, Sr. is doubtful to be the same and the payments made cannot be presumed that it is one for the main parcel, the DAR declared that the lot is vacant, due to lack of evidence.

Petitioners thus contend that the DAR Secretary’s reliance on a baseless report violated their constitutional right to due process. They claim that the DAR Secretary ignored vital documentary evidence showing that Arcadio Castro, Sr. was really the listed claimant of Lot 546 and that he had made payments for it.

ISSUE: Whether the DAR violated the constitutional right to due process of the petitioners

RULING: No. Petitioners evidence were duly considered and evaluated by said officials and all were one in concluding that Arcadio Castro, Sr. has not acquired any vested right over the subject land.

The DAR Secretary’s finding that petitioners failed to prove that the registered claimant of said land, "Arcadio Cruz" and Castro are one and the same person is based on the fact that Castro and his heirs never exerted efforts to correct the supposed error in the LTA/DAR files, and the absence of any document to show that Castro filed an application to purchase Lot 546.

As well as some of the OR indicating payments are also unreadable, and that the payments made for the “cost and rental” have no reference to Lot 546. Even if it’s true that the DAR did not have complete records before it, petitioners could have submitted those documents to them for their Petition for Review.

A party claiming a right granted or created by law must prove his claim by competent evidence. He must rely on the strength of his evidence and not on the weakness of that of his opponent.

Hence, the DAR did not violate the right to due process of the petitioners