G.R. No. 182673 - Aqualab Phil., Inc. vs. Heirs of Pagobo

Julia R. Perez, the registered owner of a 21,000‑square meter property in Barrio Batal, Santiago, Isabela, mortgaged the property to Land Bank of the Philippines.
Upon Julia’s default, the property underwent extrajudicial foreclosure and was sold at a public auction on September 30, 1997, where Land Bank emerged as the highest bidder.
Since Julia did not redeem the property within the redemption period, the ownership consolidated in Land Bank’s favor; the original Transfer Certificate of Title No. 143861 was canceled and replaced by TCT No. T‑329010 on December 4, 2002.

On June 6, 2006, Land Bank filed an ex parte petition for the issuance of a writ of possession over TCT No. T‑329010, which was granted by the Regional Trial Court on September 18, 2006.
Subsequently, the sheriff served a Demand to Vacate notice on key occupants, including Artemio Perez, Julia’s son, and Mary Basilan, who was identified as a caretaker hired by Artemio.

On September 24, 2007, Mary Basilan, Efren Basilan, and Benjamin Camiwet—claiming to be agricultural tenants—filed a Petition for the Maintenance of Peaceful Possession as Agricultural Lessee/Farmer Beneficiaries before the Department of Agrarian Reform Adjudication Board (DARAB).
The petition asserted that they had been cultivating portions of the property (with Mary tending a 3,299‑sqm lot and Efren a 17,047‑sqm lot) since 1995 and had made regular rental or lease payments initially to Julia and later to her heir, Artemio.
Additionally, a certification from the Municipal Agrarian Reform Office dated June 21, 2005, supported their claim by declaring them qualified farmer‑beneficiaries under Section 22 of the Comprehensive Agrarian Reform Law.

Following the initial issuance of the writ of possession, the Regional Trial Court later denied Land Bank’s motion to enforce or reissue the writ, holding that the agricultural tenancy was a valid third‑party claim that suspended its implementation.
On December 3, 2007, DARAB, corroborating the Municipal Agrarian Reform Office’s finding, affirmed respondents’ status as agricultural tenants and directed Land Bank to enter into a leasehold contract with Benjamin Camiwet.
Land Bank attempted to enforce an alias writ of possession through subsequent motions and filings in 2008 and 2013, but these were denied by the Regional Trial Court and later affirmed by the Court of Appeals, based on the existence of the adverse possession by agricultural tenants.

Land Bank (petitioner) filed a Petition for Review on Certiorari, contending that the respondents were merely caretakers and that their claim of agricultural tenancy was a mere afterthought intended to circumvent the writ of possession.
Respondents argued that they were bona fide agricultural tenants holding adverse title over the property, a claim supported by long‑standing possession, rental payment practices, and administrative findings.
The central dispute in the Supreme Court docket revolved around whether agricultural tenancy qualifies as a third‑party claim that bars the ex parte issuance of a writ of possession.

Did the Court of Appeals err in affirming the Regional Trial Court’s denial of Land Bank’s motion for the issuance (or re‑issuance) of a writ of possession?
Is the agricultural tenancy claim by the respondents sufficient to trigger the exception in Rule 39, Section 33, thereby suspending the writ of possession?

Whether the respondents’ long‑term occupation and cultivation of the property truly constitute agricultural tenancy with adverse possession rights, as opposed to merely being caretakers.
Whether the administrative findings (from the Municipal Agrarian Reform Office and DARAB) confirming respondents as agricultural tenants should be given deference in determining the disposition of the writ of possession.

Appropriateness of Addressing Factual Issues in a Petition for Review on Certiorari

Whether the factual issues raised by petitioner regarding the legitimacy of the respondents’ tenancy fall within the purview of a Rule 45 petition, given that factual disputes are generally not re‑examined in this type of review.