Case Digest (G.R. No. 169589)
Facts:
Joaquin Soliman, Lazaro Almario, Isidro Almario, Baldomero Almario, Demetrio Soliman, Romeo Abarin, Ernesto Tapang and Crisostomo Abarin v. Pampanga Sugar Development Company (PASUDECO), Inc. and Gerry Rodriguez, G.R. No. 169589, June 16, 2009, Supreme Court Third Division, Nachura, J., writing for the Court.The petitioners (the eight individuals named above) disputed PASUDECO’s title and possession of a ten-hectare parcel in Cabalantian, Bacolor, Pampanga. The property was originally owned by Dalmacio Sicat, who offered it for sale to PASUDECO in 1969–1970; a Deed of Sale with Mortgage between Dalmacio and PASUDECO was executed on May 22, 1970, and title registration in PASUDECO’s name followed (TCT Nos. 110325-R, 110326-R, 110327-R) in May 1974. PASUDECO planned a housing subdivision for its employees but later delayed development.
The petitioners claimed they began cultivating the land in November 1970 and produced certifications from barangay and Samahang Nayon officials and a MARO ocular inspection supporting continuous cultivation and tillage for nearly twenty years; some deposited payments with the Land Bank of the Philippines from 1989 onward. PASUDECO (through its manager, Gerry Rodriguez) maintained petitioners were interlopers and that no tenancy relationship ever existed or was consented to by PASUDECO.
The petitioners filed a Complaint for Maintenance of Peaceful Possession and a Preliminary Injunction before the Provincial Agrarian Reform Adjudicator (PARAD) in San Fernando, Pampanga. After trial and an ocular inspection, the PARAD dismissed the complaint on August 16, 1995, finding lack of direct and convincing proof of tenancy, absence of receipts for rental payments, and no consent by PASUDECO to create tenancy. Petitioners appealed to the Department of Agrarian Reform Adjudication Board (DARAB).
While the appeal was pending, lahar from Mount Pinatubo devastated the property in October 1995; PASUDECO thereafter fenced the parcel and posted private-property signs. On January 15, 2004, the DARAB reversed the PARAD, finding the land remained agricultural, that petitioners had cultivated it for almost twenty years, and that consent and sharing (or payment) were proved by conduct and deposits — thus creating tenancy by implied consent, and invoking Section 5 of Republic Act No. 3844 (Agricultural Land Reform Code). The DARAB denied PASUDECO’s motion for reconsideration in May 2004.
PASUDECO elevated the matter to the Court of Appeals (CA). The CA, in a decision dated April 12, 2005, reversed the DARAB and reinstated the PARAD, holding there was no tenancy relationship because the elements of consent and sharing were absent; the CA ruled the DARAB erred and consequently that the DARAB lacked jurisdiction. Petitioners’ m...(Subscriber-Only)
Issues:
- Whether the petitioners established that they are de jure tenants of the subject property.
- Whether the DARAB had jurisdiction to adjudicate the petitioners’ complaint (i.e., whether the case fell within agrarian jurisdiction because a tenancy relat...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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