Spouses Luciana and Pedro Dalida v.

CA and Agustin Ramos

G.R. No. L-539893, September 30, 1982

Facts:
Tomas Benitez was the bona fide and registered holder of a Revocable Permit Application issued by
the Bureau of Lands to occupy and possess a certain land. The subject land was formerly in dispute
hence, the 4,000 square meters of land covered by the said permit application was reduced to 2,200
square meters.

Tomas Benitez later on died and all his rights were conveyed to Agustin Benitez, hereon the private
respondent. Spouses Dalida, now, are advised to vacate the said land but refused to do so, alleging
that they have been the caretakers of the said land for a very long time. The Dalida’s now filed a
complaint of illegal detainer against the respondent but were later on defeated on their cause due to
the favorable decision of the court to the respondent, and pushing them to file a petition for review
on certiorari.

Issue:
Whether or not Agustin Benitez has the better right of possession to the subject land?

Held:
Yes, Agustin has the better right of possession to the subject land.

Ruling:
The petition for review on certiorari was denied and the decision of the Court of Appeals sought to be
reviewed is affirmed. TRO is lifted.

Ratio Decidendi:
The said permit application was already paid by Tomas Benitez and has to be given credence.

It is thus clear that private respondent's predecessor-in-interest was a bona fide applicant of the land
in dispute and in his favor was duly issued a permit pursuant to Revocable Permit Application.
Petitioners, on the other hand, have nothing, giving them any right to possession other than that of
mere caretakers as in the allegation of private respondent, who, by reason of the permit above
mentioned, have solid basis of their claim to the right of possession with petitioners merely as
caretakers.

There are compelling reasons of policy supporting the recognition of a right in a bona fide applicant
who has occupied the land applied for. Recognition of the right encourages actual settlement; it
discourages speculation and land-grabbing. It prevents conflicts and the overlapping of claims. It is an
act of simple justice to the diligence of the pioneer, without which land settlement can not be
encouraged or emigration from thickly populated areas hastened.