G.R. No. 191376 - Golez vs. Abais

Presentacion Golez originally filed a complaint against her brother-in-law, Mariano Abais, for ejectment from and recovery of damages over disputed agricultural lots located in Barangay Jalaud Norte, Zarraga, Iloilo.
The disputed lots were part of an Operation Land Transfer (OLT) under Presidential Decree No. 27 (PD 27), awarded to the late Ireneo Deocampo, who was a recognized farmer-beneficiary.
Presentacion alleged that after her father’s and sister’s deaths, Mariano, husband of her late sister Vicenta, unlawfully possessed the lots and refused to deliver them despite administrative orders in her favor.

Presentacion’s petition to be identified as the qualified beneficiary of the disputed lots was granted by the DAR Regional Director, as evidenced in:

The Order dated May 31, 1999 declaring her as the qualified farmer-beneficiary.
The subsequent Order dated December 11, 2000 granting her petition for reallocation.

Mariano countered by asserting that he had been in continuous cultivation for over thirty years, asserted his right as a tenant (and later as co-owner through succession), and denied any illegal disposition or mortgage of the lots.
Special affirmative defenses raised by Mariano included claims of res judicata, alleging that prior decisions (RTC and DARAB) already declared him and his wife as lawful tenants and possessor of the property.

On July 25, 2001, Provincial Adjudicator Erlinda S. Vasquez ruled in favor of Presentacion by declaring her the lawful possessor and cultivator of the disputed lots.
The ruling was based on the Rules and Regulations in Case of Death of a Tenant-Beneficiary outlined in Ministry Memorandum Circular (MC) No. 19, Series of 1978, which governs the transfer of farmholdings under PD 27.
Despite this, the ensuing legal actions involved claims for both possession and monetary damages by the parties, with Mariano filing counterclaims for moral damages, attorney's fees, and litigation expenses.

The DARAB decisions and other RTC rulings in favor of Presentacion were either limited by jurisdiction or did not amount to final judgments on the merits.
Res judicata barred Presentacion’s claim on the disputed lots given prior decisions favoring Mariano and his wife as tenants and actual cultivators.

In the CA Decision dated August 13, 2009, the court held Mariano was entitled to possession of the lots as a co-owner, anchoring its ruling on the principle of res judicata by relying on:

The RTC decision (October 1986) in Civil Case No. 16094.
The August 1996 PA Decision dismissing Presentacion’s claim against Vicenta on res judicata grounds.

Subsequent motions by Presentacion’s estate (after her passing) to reconsider these rulings and institute further relief were denied as either untimely or lacking in merit.

Following the death of Presentacion, her husband Ricarido Golez and their children substituted her in the petition.
Petitioners subsequently filed motions and requests extending time periods for the filing of a petition for review.
The proceedings culminated in a petition for review on certiorari challenging the CA Decision and seeking reinstatement of the DARAB ruling.

Whether the Court of Appeals erred in declaring Mariano Abais the lawful possessor and co-owner of the disputed lots by applying the principle of res judicata based on previous RTC and DARAB decisions.
Whether the transfer of farmholdings under PD 27, as implemented by MC 19, mandates identification of the qualified sole owner-cultivator through a separate administrative process that cannot be overruled by judicial findings emphasizing tenancy claims.