Case Digest (G.R. No. 264280)
Facts:
Rodeo v. Heirs of Burgos Malaya, G.R. No. 264280, October 30, 2024, Supreme Court Second Division, Leonen, SAJ., writing for the Court.Petitioners Florsita Rodeo, Marco Rodeo, Deborah Rodeo, Uldarico Rodeo, Jr., and Myralynn R. Hullesca (the Rodeo spouses) are descendants and successors-in-interest of caretakers who cultivated a cocoland originally cared for by Leodegario Musico and owned by Domingo Gutierrez. After Gutierrez’s death the property was managed by his daughter Araceli Gutierrez-Orola, later administered by Burgos Malaya. Upon Burgos’s death, his heirs (respondents) executed a written agreement (the Kasunduan) with the Rodeo spouses allowing them to reside on and tend the lot free of rent in gratitude for past service; the Kasunduan required that the Rodeos inform the landowners of any harvests and care for the land but contained no specific stipulation on harvest-sharing or installation as tenants.
In 2009 a member of the Malaya family allegedly ordered the Rodeo spouses to vacate and directed relatives to harvest coconuts without the Rodeos’ consent. The Rodeos filed a complaint with the Office of the Provincial Adjudicator claiming bona fide tenancy and entitlement to security of tenure. The Office of the Regional Adjudicator, in a July 29, 2016 Decision, dismissed the complaint for lack of merit, finding the Rodeos failed to prove the elements of tenancy—particularly sharing of harvests—and noting the complaint was not directly against the landowner but the heirs/administrator.
On appeal, the Department of Agrarian Reform Adjudication Board (DARAB) affirmed in a January 29, 2019 Decision, holding the Rodeos did not establish the requisite consent and sharing of harvests and that their cultivation was germane to caretaking obligations under the Kasunduan rather than indicative of an agricultural leasehold. The DARAB also found the preceding caretaker Musico was not a tenant. The Rodeos elevated the case to the Court of Appeals in CA-G.R. SP No. 160900; in a September 29, 2021 Decision the Court of Appeals denied the petition for review, agreeing that consent and sharing were not proved, and denied reconsideration in a September 19, 2022 Resolution.
The Rodeo spouses filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, arguing ...(Pro-only)
Issues:
- Are the factual findings of the agrarian adjudicatory bodies and the Court of Appeals binding on the Supreme Court in this Rule 45 petition?
- Did petitioners prove the existence of an agricultural leasehold (tenancy) between the Rodeo spouses and the heirs of Burgos Malaya (i.e., were the elements of consent and sharing ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)