Case Summary (G.R. No. 257980)
Factual Background
The case arose from a Complaint for recovery of possession filed by respondent JESUSA Y. CAILLES, through Alicia Y. Yacat, seeking to evict petitioners from a parcel in Sto. Cristo Sur, Gapan City covered by TCT No. NT-191965. The complaint alleged that petitioners and their mother executed a Sinumpaang Salaysay dated June 29, 2006 that purportedly surrendered possession and tilling rights over an 18,000-square meter portion (the subject portion) to Carlito P. Adel and his wife, Sabrina Lorenzo Adel, and that Carlito thereafter assumed possession, converted part of the land into a fishpond, and built a house without the consent of Cailles or Yacat.
Petitioners' Defense
Petitioners asserted they were poor and uneducated and were deceived into signing the subject deed, believing it to be a document evidencing a loan. They denied abandoning the land, claimed continuous cultivation, and averred that the construction of the house and the fishpond occurred with Yacat’s prior knowledge and consent. They also pointed to receipts showing payment of lease rentals to Yacat and to other representatives after the execution of the subject deed.
PARAD Ruling
In a Decision dated March 17, 2011, the Provincial Agrarian Reform Adjudication Board (PARAD) found that petitioners had abandoned the landholding as shown by the contents of the subject deed, declared the severance of the leasehold relation, and ordered petitioners and Carlito to vacate and surrender the subject portion to Cailles.
DARAB Ruling
On appeal, the Department of Agrarian Reform Adjudication Board (DARAB) in its Decision dated July 23, 2018 reversed the PARAD. The DARAB found the subject deed unpersuasive given petitioners’ limited education and their claim of deception, and it credited evidence that petitioners remained in active physical cultivation. The DARAB further found that receipts and other contemporaneous acts evidenced Yacat’s knowledge of and consent to the transactions, concluding there was no valid cause to terminate the leasehold relation.
Court of Appeals Ruling
The Court of Appeals, in a Decision dated July 7, 2020, reversed the DARAB and reinstated the PARAD Decision. The CA accorded decisive weight to the notarized subject deed, reasoning that a notarized instrument is entitled to full faith and credit absent clear, convincing, and more than preponderant evidence to the contrary. The CA emphasized the plain Filipino language of the deed, the signatures of all named parties, and the fact that the deed was prepared and notarized by petitioners’ counsel. The CA further held that petitioners violated Section 36(2) and Section 36(7) of Republic Act No. 3844 by permitting third-party possession and employment of a sub-lessee in violation of the lease, and it found receipts inadequate to prove Cailles’ consent to Carlito’s possession.
Issue Presented
The central issue before the Supreme Court was whether the Court of Appeals gravely erred in ruling that there was sufficient basis to evict petitioners from the subject land.
Standard of Review and Scope of Reassessment
The Court noted that under Rule 45, Rules of Court, only questions of law are generally reviewable, and factual findings of administrative or quasi-judicial bodies are afforded respect when supported by substantial evidence. The Court recognized, however, that it may reassess facts where the findings are conflicting among tribunals, and it exercised that limited power because the PARAD, the DARAB, and the CA reached divergent factual conclusions.
Legal Principles Governing Notarized Instruments and Abandonment
The Court agreed with the CA that a notarized instrument is presumptively entitled to full faith and credit on its face, absent clear, convincing, and more than preponderant evidence to rebut it, citing precedents. The Court also recited the established elements required to sustain a claim of abandonment under Republic Act No. 3844 and jurisprudence: (a) a clear and absolute intention to renounce or desert the right; and (b) an external act manifesting that intention, typically a factual failure or refusal to work the landholding for a specified period. The Court emphasized that abandonment ordinarily requires an absence of cultivation or relinquishment of possession for at least two calendar years as articulated in Corpuz v. Grospe and related authorities.
Application of Law to the Facts
Applying these principles, the Court found the subject deed clear on its face in surrendering possession and tilling rights. The Court nonetheless held that the requisites for abandonment were not satisfied. Less than two calendar y
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Parties and Posture
- Rodolfo A. Dela Cruz and Celerino A. Dela Cruz were petitioners before the Court seeking review of the Court of Appeals' decision and resolution that reinstated a PARAD eviction order.
- Jesusa Y. Cailles, represented by Alicia Y. Yacat was the respondent and owner-claimant of the land covered by TCT No. NT-191965.
- The petition challenged the Court of Appeals ruling in CA-G.R. SP No. 160682 that reversed the DARAB decision and reinstated the PARAD decision ordering ejectment.
- The Court adjudicated the petition under Rule 45 and emphasized that only questions of law are ordinarily reviewable on certiorari but allowed reexamination of facts due to conflicting findings.
Key Facts
- The subject land was a parcel in Sto. Cristo Sur, Gapan City, covered by TCT No. NT-191965 in Jesusa Y. Cailles' name.
- On June 29, 2006, the Dela Cruzes and their mother executed a notarized Sinumpaang Salaysay purportedly surrendering possession and tilling rights over an 18,000-square meter portion to Carlito P. Adel and Sabrina Lorenzo Adel.
- Carlito assumed possession, converted part of the holding into a fishpond and built a house without alleged consent from Cailles or Yacat according to the complaint.
- Receipts showing payment of lease rentals in the names of Encarnacion Dela Cruz and Rodolfo "Rudy" Dela Cruz were issued after the execution of the subject deed and adjacent farmers corroborated continued cultivation by the Dela Cruzes.
- A December 4, 2007 document executed before the barangay captain acknowledged full payment of a loan and affirmed that Rodolfo and Daniel Dela Cruz were cultivating the parcel.
Procedural History
- The complaint for recovery of possession was filed before the Provincial Agrarian Reform Adjudication Board (PARAD) and resulted in a March 17, 2011 decision declaring severance of the leasehold relation and ordering surrender.
- The Dela Cruzes appealed to the Department of Agrarian Reform Adjudication Board (DARAB), which on July 23, 2018 reversed PARAD and ordered the maintenance of the Dela Cruzes' peaceful possession.
- Jesusa Y. Cailles appealed to the Court of Appeals, which on July 7, 2020 reversed DARAB and reinstated PARAD, a ruling affirmed in a March 23, 2021 denial of reconsideration.
- The Dela Cruzes filed the present petition for review on certiorari before the Supreme Court.
Issue Presented
- The central issue was whether the Court of Appeals gravely erred in finding sufficient grounds to evict the Dela Cruzes by treating the notarized surrender deed as dispositive of abandonment and leasehold severance.
Ruling
- The petition was gran