G.R. No. 131903 - Badillo vs. Court of Appeals

Petitioners: Rodolfo A. dela Cruz and Celerino A. dela Cruz, agricultural lessees of a parcel of land.
Respondent: Jesusa Y. Cailles, landowner, represented by Alicia Y. Yacat.
Subject Land: Parcel located in Sto. Cristo Sur, Gapan City, titled under TCT No. NT-191965.

Cailles filed a Complaint for recovery of possession before the Provincial Agrarian Reform Adjudication Board (PARAD) to evict the Dela Cruzes and Carlito Adel from the subject land.
Cailles claimed that the agricultural lessees (Dela Cruzes) and their mother, Encarnacion Dela Cruz, executed a Sinumpaang Salaysay (Voluntary Surrender) on June 29, 2006, in favor of Carlito Adel and his wife, erroneously representing ownership by Yacat.
Carlito took possession and tilled the land without Cailles’ or Yacat's consent; converted part into a fishpond and constructed a house.
Cailles learned of this in June 2007 and attempted to recover land through Yacat, but was unsuccessful, prompting the Complaint.

Claimed they were poor and uneducated and were deceived into signing the voluntary surrender deed, under the impression it was proof of a loan transaction.
Asserted that Carlito’s house was built with Yacat’s permission and that the fishpond was constructed by spouses Orlando and Susan Adel with Yacat’s approval.

Determined the Dela Cruzes abandoned the land as evidenced by the voluntary surrender deed.
Declared termination of leasehold relationship and ordered the Dela Cruzes to vacate the land.

Reversed the PARAD decision.
Found the surrender deed unconvincing due to the Dela Cruzes’ alleged ignorance and coercion.
Recognized continued active cultivation and receipt of lease payments post-deed.
Affirmed Dela Cruzes' rights to peaceful possession.

Reversed the DARAB decision.
Held the notarized voluntary surrender deed is entitled to full faith and credit absent clear and convincing evidence.
Noted that all parties understood the deed’s plain Filipino language meaning.
Found Dela Cruzes violated R.A. 3844’s provisions by allowing non-lessee Carlito to possess and till the land.
Disregarded lease payment receipts as evidence of consent to Carlito’s possession.

Denied the Dela Cruzes’ motion for reconsideration, upholding its prior decision.

The Dela Cruzes filed a Petition for Review on Certiorari challenging the CA decisions.

Whether the Court of Appeals gravely erred in finding that sufficient cause existed to evict the Dela Cruzes, thereby terminating their leasehold relation.