G.R. No. 165155 - Regional Agrarian Reform Adjudication Board vs. Court of Appeals

Respondents are co-owners of several parcels of land devoted to rice production covering 58.8448 hectares in Sta. Barbara, Baliuag, Bulacan, covered by Transfer Certificates of Title (TCT) Nos. T-158564, T-215772, T-215776, T-215777, T-215775.
Petitioners are in actual possession of the land as tillers, claiming status as farmer-beneficiaries under Presidential Decree 27 with Certificates of Land Transfer (CLTs) and unregistered emancipation patents (EPs). Respondents contend petitioners are agricultural lessees obligated to pay annual lease rentals.

On March 6, 2002, respondents filed a complaint for ejectment against petitioners before the Department of Agrarian Reform Adjudication Board (DARAB), Office of the Regional Adjudicator, San Fernando Pampanga, alleging non-payment of rentals since 1994. The case was docketed as DARAB Case No. R-03-02-0213-Bul ’02.
Named defendants included Avelino Santos and Pedro Bernardo who were deceased at time of filing; their heirs, Delfin Sacdalan and Roberto Bernardo respectively, participated in the case though formal substitution was not made.
Both petitioners’ and respondents’ position papers acknowledged the heirs as parties to the case and no contention was raised on such participation.

The Regional Adjudicator ruled in favor of respondents, severing and extinguishing the tenancy/agricultural leasehold relationship due to petitioners’ failure to pay rentals since 1994.
Petitioners were ordered to vacate the land, remove improvements, pay rentals due, and P300,000 as liquidated damages. The decision was based on land exempted from Comprehensive Agrarian Reform Program (CARP) coverage as per a December 18, 1992 Department of Agrarian Reform (DAR) order directing cancellation of CLTs/EPs.

Petitioners filed two separate notices of appeal on February 28 and March 5, 2003, respectively. Both were signed only by parties without counsel’s signature.
Respondents filed a motion to dismiss the appeal alleging: failure to state specific grounds for appeal, late filing of the second notice, and forgery of signatures of deceased defendants Avelino and Pedro on the second notice.

On May 6, 2003, the Regional Adjudicator allowed the appeals except for those pertaining to deceased defendants due to alleged forged signatures, and issued a writ of execution against non-appealing defendants.
Petitioners contested the order citing lack of opportunity to question and asserting the signatures were by widows acting for heirs.
A hearing on July 3, 2003 established the widows admitted signing on behalf of deceased spouses intending to appeal.
August 5, 2003 Order of the Regional Adjudicator gave due course to appeal by heirs, nullified the writ of execution as to them, and allowed their appeals despite signature issues, emphasizing justice and equity over technical defects.
Respondents moved for reconsideration but were denied on November 13, 2003 and January 9, 2004.

Respondents filed a certiorari petition before the CA arguing DARAB lacked jurisdiction to reverse executed portion and that notices of appeal were invalid for failure to state grounds and containing forged signatures.
The CA ruled the notices of appeal were "mere scraps of paper" for failure to state specific grounds and declared the second notice void due to forgery, denying petitioners’ motion for reconsideration.

Petitioners argued substantial compliance with DARAB rules, emphasizing liberal construction especially in agrarian cases.
They asserted the error on forgery was innocent given their status as heirs participating in the proceedings and the complaint was originally filed against deceased predecessors-in-interest.
Respondents maintained strict procedural compliance and the invalidity of notices of appeal, emphasizing that forgery should not be condoned.
Petitioners also raised for the first time that the exemption order relied on by Regional Adjudicator was fabricated, seeking nullification. Respondents argued the issue was settled in another case and was factual in nature.

Whether the Notices of Appeal dated February 28, 2003 and March 3, 2003 are “mere scraps of paper” for failure to state the grounds relied upon for appeal.
Whether the Notice of Appeal dated March 3, 2003 is null and void for allegedly containing two forged signatures of deceased defendants.
Whether the purported exemption order exempting respondents’ land from CARP coverage is a fabrication affecting petitioners’ obligation to pay rentals.