Case Summary (G.R. No. 260650)
Factual Antecedents
The litigation began when Natividad filed a petition for ejectment and collection of back lease rentals against the respondents on December 23, 1998, following his alleged purchase of the property. His demand for lease payments was declined by the respondents, who claimed they had been making payments to the original landowners and, consequently, contested Natividad's ownership. The Provincial Agrarian Reform Adjudicator (PARAD) ruled in favor of Natividad in a decision rendered on October 27, 1999.
Procedural History
Despite being served summons, the respondents did not answer the ejectment petition, leading to a decision that became final and executory when they failed to appeal. On May 4, 2000, the respondents first filed for relief from judgment citing excusable negligence, which the PARAD denied for lack of sufficient grounds. A second petition was similarly denied. The Department of Agrarian Reform Adjudication Board (DARAB) later allowed the respondents' appeal, overturning the PARAD's ruling on February 21, 2005.
Ruling of the DARAB
DARAB found that Natividad had not substantiated his claim of non-payment, relying instead on the respondents' payment receipts and their assertion of rightful occupancy under a Certificate of Land Transfer (CLT). The DARAB ordered Natividad to allow the respondents to remain in possession while also mandating them to pay any verified back rent.
Ruling of the Court of Appeals
Upon Natividad's appeal, the Court of Appeals (CA) affirmed the DARAB’s decision on November 28, 2006, concluding that Natividad failed to provide sufficient proof of the respondents' non-payment of lease rentals. The CA emphasized that under the agrarian reform laws, a landowner must demonstrate legal grounds to eject tenants, which Natividad did not do.
Arguments by the Petitioner
Natividad contested the appellate court's findings, asserting that the respondents failed to show knowledge of his ownership and the illegitimacy of their lease payments to the former owners. He argued against the reopening of the PARAD’s decision, invoking the doctrine of immutability of judgments.
Arguments by the Respondents
The respondents maintained that they had valid rights over the property through the CLT and alleged that Natividad's ownership was legally deficient. They argued that eviction due to non-payment requires clear and undeniable proof of willful neglect, which they contended was absent in this case.
The Issue
The primary issue revolves around whether Natividad had justifiable grounds to eject the respondents from the property.
Decision of the Supreme Court
The Supreme Court denied Natividad's petition. It underscored that the primary consideration of laws governing agrarian reform, specificall
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Case Overview
- This case revolves around a petition for review on certiorari filed by Ernesto L. Natividad against Fernando Mariano, Andres Mariano, and Doroteo Garcia, challenging the decision of the Court of Appeals.
- The Court of Appeals affirmed the ruling of the Department of Agrarian Reform Adjudication Board (DARAB), which reversed an earlier decision by the Provincial Agrarian Reform Adjudicator (PARAD) concerning the ejectment of the respondents from a parcel of agricultural land.
Factual Antecedents
- The subject of the dispute is a 66,997 square meter agricultural land in Sitio Balanti, Gapan, Nueva Ecija, owned by Esperanza Yuzon.
- Ernesto Natividad filed for ejectment and collection of back lease rentals against the respondents who were tenants on the land, claiming he bought the property in a public auction in July 1988.
- Natividad alleged that after purchasing the property, he demanded lease rentals from the respondents, who failed to pay, leading him to file the ejectment petition.
- The PARAD ruled in favor of Natividad in October 1999 and ordered the respondents to vacate and pay back rentals. The decision became final as the respondents did not appeal.
- Respondents later filed a petition for relief from judgment citing excusable negligence and lack of knowledge about agrarian reform laws, which was denied by PARAD.
- A second petition was also denied, leading to an appeal to DARAB, which granted the respondents' appeal, reinstating their possession and ordering them to pay back rentals.
Ruling of the DARAB
- The DARAB found insufficien