Facts:

This case involves a petition for review filed by Automat Realty and Development Corporation, along with its representatives Lito Cecilia and Leonor Lim, against spouses Marciano Dela Cruz, Sr. and Ofelia Dela Cruz. The petition was filed on October 1, 2014, and the matter had its origins in a dispute over land occupancy and tenancy rights in Barangay Malitlit, Sta. Rosa, Laguna. The registered owners, Automat Realty, acquired two parcels of land in 1990, identified as TCT Nos. T-210027 and T-209077, wherein one parcel measured 49,503 square meters, while the other measured 24,562 square meters. The land was initially unoccupied, prompting petitioner Lim to allow respondent Ofelia Dela Cruz to act as a caretaker to prevent informal settlers from encroaching on the property. Respondent spouses cultivated and improved the land while reportedly paying rents through the appointed representative, petitor Lito Cecilia. In August 2000, Automat requested the respondents to vacate the pr

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Facts:

Ownership and Acquisition of the Property

• Petitioner Automat Realty and Development Corporation is the registered owner of two parcels of land in Barangay Malitlit, Sta. Rosa, Laguna, covered by TCT Nos. T-210027 and T-209077.
• The 49,503-square-meter parcel (TCT No. T-209077) was acquired from El Sol Realty and Development Corporation and the 24,562-square-meter parcel (TCT No. T-210027) from Ofelia Carpo in 1990.
• Petitioner Leonor Lim, acting as the real estate broker, was involved in the property's acquisition; she received a share in the broker’s fees from the seller or buyer.

Initial Occupation and Caretaking Arrangement

• At the time of purchase, the property was unoccupied.
• Respondent Ofelia Dela Cruz volunteered to act as caretaker to prevent informal settlers from occupying the land.
• An agreement was reached—through petitioner Lim and on behalf of Automat—stipulating that the caretaker would vacate the premises upon demand.

Tenant Occupation and Cultivation

• The respondent spouses, as rent-paying tenants, occupied the property, cultivated, and improved the land.
• The harvest (palay/rice) was shared with Automat through its authorized agent, petitioner Lito Cecilia, and rental payments were remitted accordingly.
• In August 2000, Automat requested that the respondent spouses vacate the property to prepare it for development; however, they refused without compensation, asserting their right as agricultural tenants.

Dispute Initiation and Proceedings

• On October 19, 2000, the respondent spouses filed a petition for the maintenance of peaceful possession with prayer for a preliminary mandatory injunction and/or temporary restraining order before the Provincial Agrarian Reform Adjudicator (PARAD) for Laguna.
• Before the filing of the petition, Automat had already recovered possession of the property.
• On August 28, 2001, the PARAD dismissed the complaint, ruling that no agricultural tenancy relationship could be established because the property was classified as residential, commercial, and industrial land.

Reversal by the DARAB and Subsequent Appeals

• On February 8, 2005, the Department of Agrarian Reform Adjudication Board (DARAB) overturned the PARAD decision, declaring the respondent spouses as de jure tenants entitled to security of tenure.
• Petitioners Automat, Lim, and Cecilia appealed the DARAB ruling, arguing lack of evidence of an agricultural tenancy, improper jurisdiction (since the land was non-agricultural), and absence of essential requisites for tenancy.
• On August 19, 2009, the Court of Appeals affirmed the DARAB decision, using documentary evidence such as:
• A MARO certification (Job A. Candanido’s October 18, 2000 certification) stating that the respondent spouses were the actual tillers of the land.
• Sworn statements from neighbors and adjacent lot owners.
• Certifications from the Irrigation Superintendent regarding payment of service fees.
• Check evidence of rental payments.
• Petitioners subsequently filed for reconsideration, supplemented by the submission of two DAR exemption orders (dated March 30, 2010) which exempted the property from the Comprehensive Agrarian Reform Program (CARP).

Resolution of the Dispute and Jurisdictional Issue

• The primary issues revolved around the existence of an agricultural tenancy relationship and whether the DAR exemption orders nullified DARAB’s jurisdiction.
• The facts regarding tenants’ cultivation, acceptance of rental payments, and the contractual or implied arrangements as caretaker and tenant were heavily scrutinized in light of the property’s classification history and applicable agrarian laws.

Issue:

Existence of an Agricultural Tenancy Relationship

• Whether the elements constituting an agricultural tenancy relationship were present, including:
• Relationship between landowner and tenant.
• Subject matter being agricultural land.
• Consent and an implied or express agreement.
• Purpose of agricultural production with personal cultivation and harvest sharing.
• Whether evidence such as the MARO certification and rental payment records sufficiently established the tenancy claim.

Jurisdictional Effect of the DAR Exemption Orders

• Whether the DAR exemption orders issued on March 30, 2010, which reclassified the land as non-agricultural prior to the CARL’s effectivity, nullify the jurisdiction of the DARAB over the dispute.
• Whether, in view of the exemption orders, the earlier decisions of DARAB and the PARAD should be considered void for lack of jurisdiction over a non-agricultural matter.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)