Case Summary (G.R. No. 257980)
Facts of the Case
The dispute arose from a Complaint for recovery of possession filed by Cailles against Dela Cruz et al. in the Provincial Agrarian Reform Adjudication Board of Cabanatuan City (PARAD). Cailles alleged that Dela Cruz et al. abandoned their lease and executed a Voluntary Surrender document in favor of Carlito Adel, who misrepresented the land as belonging to Yacat. Cailles claimed that Dela Cruz et al. had been evicted from the land due to the actions of Carlito without her consent.
In their defense, Dela Cruz et al. contended that they were deceived into signing the document under the pretense that it confirmed a loan. They further claimed that any actions taken by Carlito regarding the land were with Yacat's permission.
Initial Rulings
The PARAD ruled on March 17, 2011, that Dela Cruz et al. had indeed abandoned the leasehold, leading to their eviction. This decision was subsequently challenged by Dela Cruz et al. and brought before the Department of Agrarian Reform Adjudication Board (DARAB), which, in its ruling dated July 23, 2018, found in favor of Dela Cruz et al., asserting that there was insufficient evidence to justify the termination of the leasehold relationship.
Court of Appeals Decision
Dissatisfied with the DARAB's ruling, Cailles appealed to the Court of Appeals (CA), which issued a decision on July 7, 2020. The CA reversed the DARAB decision, reinstating the PARAD ruling, primarily emphasizing the validity of the notarized Voluntary Surrender document and asserting that Dela Cruz et al. had violated their obligations as tenants.
Legal Issues
The essential issue for the Supreme Court's consideration was whether the CA erred in concluding that there were sufficient grounds for the eviction of Dela Cruz et al. The Court evaluated the compliance with legal standards pertinent to agricultural leasehold agreements, particularly focusing on the requirements for proving intent to abandon the lease as outlined under Republic Act No. 3844.
Supreme Court Ruling
The Supreme Court granted the Petition and found merit in Dela Cruz et al.'s claims. It underscored that only questions of law were to be addressed under a petition per Rule 45 of the Rules of Court and noted conflicting factual findings between the CA and DARAB. The Court reaffirmed the principle that a notarized document is presumptively valid absent compelling evidence to the contrary.
The Court found that
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Background and Procedural History
- The case involves a Petition for Review on Certiorari assailing the Court of Appeals' Decision dated July 7, 2020, and Resolution dated March 23, 2021, in CA-G.R. SP No. 160682.
- The Court of Appeals reversed and set aside the Decision dated July 23, 2018, of the Department of Agrarian Reform Adjudication Board (DARAB), and reinstated the Decision dated March 17, 2011 of the Provincial Agrarian Reform Adjudication Board of Cabanatuan City (PARAD).
- The PARAD declared the severance of the leasehold relationship between respondent Jesusa Y. Cailles (Cailles) and the agricultural lessees, the Dela Cruzes, and ordered them to vacate and surrender the subject land.
Facts of the Case
- Jesusa Y. Cailles, through Alicia Y. Yacat, filed a Complaint for recovery of possession before PARAD seeking to evict the Dela Cruzes from a parcel of land located in Sto. Cristo Sur, Gapan City, covered by TCT No. NT-191965.
- Respondent alleged that the Dela Cruzes and their mother executed a Sinumpaang Salaysay (Voluntary Surrender) dated June 29, 2006, in favor of Carlito Adel and his wife over an 18,000 sq.m. portion of the land, misrepresenting ownership.
- Carlito assumed possession and tilling rights over the subject portion without Cailles' or Yacat's consent, converted part into a fishpond, and constructed a house without consent.
- Upon learning of this possession, Cailles sought recovery through Yacat but eventually filed the complaint asserting abandonment and termination of the leasehold.
- The Dela Cruzes countered that they were deceived into signing the subject deed, believing it to be a loan proof; they claimed prior consent to the house construction and that the fishpond was constructed by others with Yacat's consent.
Decisions and Rulings Prior to the Supreme Court
- PARAD Decision (March 17, 2011): Ruled that the Dela Cruzes abandoned