G.R. No. 179643 - Natividad vs. Mariano

The case involves a 66,997 square meter agricultural land (subject property) located in Sitio Balanti, Gapan, Nueva Ecija, registered in the name of Esperanza Yuzon under Transfer Certificate of Title No. NT-15747.
The respondents are the tenants of the subject property.
Ernesto L. Natividad, who asserted his title acquired through a public auction on July 17, 1988, initiated the dispute by filing a petition for ejectment and collection of back lease rentals against the respondents.

On December 23, 1998, Ernesto filed his petition with the PARAD, alleging that he had purchased the subject property and that, following his verbal demands for lease rental payments, the respondents refused to pay and vacate the land.
The respondents, having been duly served with summons, failed to answer—resulting in their waiver of the right to present evidence.
Consequently, the PARAD allowed the case to proceed ex parte and rendered its decision on October 27, 1999, granting Ernesto’s petition based solely on his unrebutted allegations.
With the respondents not appealing the decision, the PARAD’s ruling became final and executory, leading to the issuance of a writ of execution on April 6, 2000.

On May 4, 2000, the respondents, represented by a private law firm, filed a first Petition for Relief from Judgment based on excusable negligence, citing inexperience, ignorance of relevant agrarian reform laws, and financial constraints.
The PARAD denied this petition on June 7, 2000, holding that no grounds for relief existed and noting that the petition had been filed out of time.
A second petition was subsequently filed on June 23, 2000, with similar allegations and an additional claim of indigence; however, the PARAD again denied the petition on technical grounds.
The respondents then appealed the PARAD’s decision to the Department of Agrarian Reform Adjudication Board (DARAB).

On February 21, 2005, the DARAB reversed the PARAD’s decision by granting the respondents’ appeal, thereby ordering Ernesto to maintain the respondents in possession of the property while directing them to pay arrears as computed by the Municipal Agrarian Reform Officer (MARO).
Ernesto then elevated the case by filing a petition for review under Rule 43 before the Court of Appeals.
On November 28, 2006, the CA denied Ernesto’s petition for review, finding that he lacked clear, positive, and convincing evidence of non-payment of lease rentals, and emphasizing that the respondents had been paying rental receipts through Corazon and Laureano, properly sanctioned as payees.
Ernesto further challenged the CA ruling by filing a petition for review on certiorari under Rule 45.

Ernesto argued that the CA erred in finding that he had authorized Corazon and Laureano to receive the lease rentals on his behalf, and claimed that the respondents’ alleged non-payment did not constitute sufficient ground for ejectment.
He contended that the respondents were excused due to their ignorance of the legality of his acquisition of the property and that the finality of the PARAD’s decision should not be subject to reopening or modification under the doctrine of immutability of judgments.
The respondents, meanwhile, contended that Ernesto’s purchase was null and void based on the rights acquired by Diego and Doroteo from Certificates of Land Transfer issued in 1973, and argued that under agrarian laws his prolonged inaction and the issuance of CLTs validated their continued possession.

Whether Ernesto had established sufficient cause to eject the respondents from the subject property.

Whether there was clear and convincing evidence of non-payment of lease rentals by the respondents.
Whether Ernesto’s alleged verbal demands for payment were substantiated by evidence.

Whether the respondents’ failure to promptly seek relief or appeal (alleged excusable negligence) bars the reopening of the PARAD’s decision.

The effect of procedural defaults and the timeliness of the respondents’ petitions for relief from judgment.

Whether the reopening or modification of the final and executory PARAD decision is permissible under the doctrine of immutability of judgments.

Whether the exception to immutability applies in cases where justice and equity demand a re-evaluation of substantial evidence.

The validity of the respondents’ payment of lease rentals to Corazon and Laureano as authorized payees, notwithstanding Ernesto’s assertion to the contrary.

Whether respondents’ consistent practice of paying through designated representatives constitutes a valid mode of payment.