Case Digest (G.R. No. 257980)
Facts:
Rodolfo A. Dela Cruz and Celerino A. Dela Cruz, Petitioners, v. Jesusa Y. Cailles, represented by Alicia Y. Yacat, G.R. No. 257980 (Formerly UDK-16986), June 26, 2024, Supreme Court Second Division, Kho, Jr., J., writing for the Court. Petitioners are agricultural lessees; respondent Jesusa Y. Cailles, through Alicia Y. Yacat, is the registered owner of the land subject of the dispute (TCT No. NT-191965) located in Sto. Cristo Sur, Gapan City.The dispute began with a Complaint for recovery of possession filed by Cailles before the Provincial Agrarian Reform Adjudication Board of Cabanatuan City (PARAD), asserting that petitioners and their mother executed a notarized Sinumpaang Salaysay dated June 29, 2006 (the “subject deed”), by which they surrendered an 18,000-square meter portion of the land (the “subject portion”) in favor of Carlito P. Adel and his wife. Cailles alleged that Carlito thereafter assumed possession, converted part of the land into a fishpond and built a house, all without Cailles’s consent, and that the Dela Cruzes had thereby abandoned the tenancy and should be evicted.
In a Decision dated March 17, 2011, the PARAD found abandonment and ordered the Dela Cruzes and Carlito to vacate and surrender the subject portion to Cailles. The Dela Cruzes appealed to the Department of Agrarian Reform Adjudication Board (DARAB).
In a Decision dated July 23, 2018, the DARAB reversed the PARAD, holding that the notarized deed was not sufficiently convincing because the Dela Cruzes — characterized as poor and uneducated — were allegedly coaxed into signing a document they believed to be proof of a loan; DARAB found evidence of continued cultivation and receipts of lease payments to Yacat that corroborated the Dela Cruzes’ continued possession and tilled status, and it ordered Cailles to respect their peaceful possession.
Cailles appealed to the Court of Appeals (CA). In a Decision dated July 7, 2020, the CA reversed DARAB and reinstated the PARAD ruling, giving conclusive weight to the notarized deed as a plain Filipino-language instrument signed and notarized (by the Dela Cruzes’ counsel, Atty. Mario M. Pangilinan), and finding violations under Section 36(2) a...(Subscriber-Only)
Issues:
- May the Supreme Court relax the Rule 45 restriction on reexamination of factual findings and reassess conflicting factual findings made below?
- Was there sufficient legal and factual basis to terminate the agricultural leasehold relation and evict the Dela Cruzes for abandonment or other...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)