G.R. No. 152564 - Bautista vs. Vda. de Villena

The dispute centers on an agricultural lot, designated as Lot No. 26, located at Poblacion, San Rafael, Bulacan, covered by Transfer Certificate of Title No. RT-6304.
This lot, along with an adjacent parcel of 2A12 hectares, was originally owned by Maria Lopez Caluag (or a Caluag), who is now deceased.
The original tenant-tiller of the agricultural land was the late Aquilino Villena, husband of the respondent, Susana Mag-Isa Villena. The tenancy relationship began in 1946 and continued even after Aquilino’s demise, being maintained by Susana.

In 1957, under the instruction of Maria Lopez Caluag, a portion of the subject lot (with an area of 1,000 square meters) was transferred to Susana as a home lot and seedbed, where she constructed her house.
Susana remained in peaceful possession of the home lot from 1957 until 1987, when an ejectment case was filed against her by petitioners.

In 1987, petitioners Eugenio Bautista, Romeo Cruz, and Carmencita B. Cruz initiated an ejectment action against Susana.
The ejectment case did not prosper. Subsequently, on March 26, 1990, the petitioners filed an action for quieting of title and recovery of possession at the Regional Trial Court (RTC) of Bulacan.
The RTC ruled in favor of the petitioners, prompting the respondent to appeal.
The Court of Appeals (CA) reversed the RTC’s decision, ruling that as a tenant of the previous owner, the respondent was entitled to her home lot and that disputes regarding the tenancy and the home lot right fell under the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB).

Testimonies from several witnesses—including petitioners’ own witness Eugenio Bautista, as well as Angelina Caluag and Atty. Jose Caluag—established indisputably that Susana was a tenant of Maria Lopez Caluag and later of the transferees.
These judicial admissions confirmed the tenancy relationship, making further evidence unnecessary.
The factual matrix supported the existence of a tenancy relationship dating from as early as the 1950s.

Whether the case falls within the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB) pursuant to Executive Order 129-A.

Whether the dispute—centered on the tenant’s right to retain her home lot as part of her tenancy rights—should be adjudicated by the DARAB rather than by the regular courts.

Whether the respondent’s established tenancy relationship, and her accompanying right to a home lot, survives the transfer of legal possession from the original owner to the petitioners.