G.R. No. 140796 - Perez-Rosario vs. Court of Appeals

The petitioners, Purificacion Perez-Rosario and others, filed a petition for certiorari under Rule 65 of the Rules of Court against the Court of Appeals and the Adjudication Board of the Department of Agrarian Reform (DARAB).
The case originated from an ejectment action due to non-payment of lease rentals and unauthorized sub-leasing of a 2.2277-hectare agricultural land in Pangasinan.
The land was registered under the name of Nicolasa Tamondong Vda. de Perez, the predecessor of the petitioners, who sold the property with a right to repurchase to respondent Miguel Resultay.

After the sale, Miguel Resultay failed to deliver the agreed shares of the rice harvest, leading to the involvement of Basilio Cayabyab as a lessee of a portion of the land.
Following Nicolasa's death in 1977, the petitioners repurchased the property in 1983, after which Miguel Resultay resumed delivering his share of the harvest.
The petitioners filed for ejectment in 1988, citing insufficient delivery of harvests and unauthorized construction of houses by the respondents.

The respondents contended that they were legitimate agricultural tenants and that the allegations of non-payment and unauthorized sub-leasing were unfounded.
They argued that the construction of houses was for practical purposes and that the net harvests were shared according to the agreement.

The Office of the Provincial Agrarian Reform Adjudicator ruled in favor of the petitioners, declaring Mercedes Resultay as the successor tenant and dispossessing Cayabyab for non-payment of lease rentals.
The DARAB later reversed this decision, affirming the status of the respondents as agricultural tenants and maintaining Cayabyab's position as a bona fide agricultural lessee.

The Court of Appeals upheld the DARAB's ruling, stating that the evidence did not support the petitioners' claims of non-compliance by the respondents.
The CA found that the hiring of farm laborers was permissible and that the respondents had been actively cultivating the land and paying their dues.

The petitioners filed a petition for certiorari, arguing that the lower courts misapprehended the facts and misapplied the law regarding agricultural tenancy.
They contended that the declarations of the respondents as agricultural lessees were contrary to established facts and jurisprudence.

The Court noted that the petitioners had an adequate remedy through an appeal under Rule 45, which they failed to pursue within the reglementary period.
The petition for certiorari was deemed a substitute for the lost right to appeal, which is not permissible under the rules.

The Court emphasized that the burden of proof rested on the petitioners to demonstrate lawful grounds for ejectment, which they failed to do.
The Court reiterated that the employment of farm laborers does not negate the existence of an agricultural leasehold relationship, provided the...continue reading