G.R. No. 140164 - Reyes vs. Reyes

The case involves a dispute over the tenancy rights to a two-hectare agricultural lot in Parulan, Plaridel, Bulacan, owned by the late Marciano Castro.
The parties are siblings: petitioner's Dionisia L. Reyes, and respondents Ricardo L. Reyes, Lazaro L. Reyes, Narciso L. Reyes, and Marcelo L. Reyes.
The dispute arose after the death of their father, Felizardo J. Reyes, who was the original tenant of the property.

Prior to his death (February 17, 1989), Felizardo Reyes cultivated the agricultural lot.
Following his death, petitioner's claim is based on a leasehold contract executed on November 6, 1989 between Dionisia and the Castros, naming her as the substitute or designated lessee in place of her deceased father.
Respondents, however, occupied a one-hectare portion of the land by force before the commencement of the planting season in 1989 and began paying rent to the property overseer, Armando Duran.

The Department of Agrarian Reform Adjudication Board (DARAB) and its Provincial Adjudicator ruled in favor of petitioner Dionisia Reyes, affirming her security of tenure based on the written leasehold contract.
Respondents initially claimed to have inherited the tenancy rights from their deceased father but later shifted their theory, asserting that an implied tenancy had arisen when Armando Duran, acting as overseer, accepted rental payments from them.
The alleged implied tenancy rested on the supposed authority of Duran to bind the landowner through his long tenure (16 years as overseer), which respondents argued created an agency relationship that validated their occupation.

The case was first resolved by the DARAB Region III Provincial Adjudicator in DARAB Case No. 249-Bul-91, ruling in favor of petitioner.
The DARAB-Central Office subsequently affirmed the ruling, dismissing the appeal filed by respondents.
Respondents then elevated the case to the Court of Appeals via CA-G.R. SP No. 47033, where they introduced their new theory of an implied tenancy, resulting in the reversal of the DARAB decision.
The central question for the higher court was to determine who among the siblings was the lawful and rightful tenant of the Castro property.

Disregarding the substantial evidence rule and substituting its own findings of fact over the binding findings of the DARAB and its Provincial Adjudicator.
Accepting a new theory of implied tenancy contrary to the established and evidenced facts.

Whether the acceptance of rental payments by Armando Duran, as overseer, legitimately constituted authority to appoint or imply tenancy rights.
Whether the actions of Duran, purportedly acting as an agent of the Castro family, could estop the landowners from denying the existence of a tenancy relationship with respondent Ricardo Reyes and his siblings.

Whether the petitioner's leasehold contract designating her as the substitute tenant was valid and should prevail over any claim of an implied tenancy by the respondents.