G.R. No. 241353 - Romero vs. Sombrino

Case Summary (G.R. No. 241353)

Factual Background

The controversy concerned a two-hectare portion of Lot No. 23, Pls-35 at Marauding Annex, Kapatagan, Lanao del Norte (subject property), part of a 12.0717-hectare tract registered under Original Certificate of Title No. P-2261 in the name of Lutero after his homestead application was approved in 1967. Respondent Sombrino asserted that she and her late husband were installed as tenants of the subject property in 1952 by the alleged original owners, the Spouses Eugenio and Teodora Saltiga de Romero (Sps. Romero), and she sought to assert security of tenure following her ouster pursuant to execution of a final judgment that recognized Lutero's ownership.

Prior Final Judgment in De Romero v. CA

Prior to the agrarian proceedings, ownership of the subject property had been litigated in consolidated civil cases culminating in a final and executory decision of the Court in Teodora Saltiga de Romero, et al. v. Court of Appeals, et al. (referred to in the decision as De Romero v. CA). The Court in De Romero v. CA held that Lutero was the true and lawful owner by virtue of a valid homestead patent granted in 1967, that the Sps. Romero never owned the land because Eugenio had been disqualified from obtaining a patent, and that alleged affidavits of sale executed by Lutero were null and void under Section 118 of Commonwealth Act No. 141 as then interpreted.

RTC Proceedings and Enforcement

After the decision in De Romero v. CA became final and executory, the petitioners Heirs of Lutero procured a Writ of Execution from the Regional Trial Court and the writ was implemented following a hearing in which respondent Sombrino unsuccessfully sought intervention as a tenant. The RTC issued a Writ of Demolition, and respondent Sombrino was ousted from the subject property on April 5, 2005.

PARAD Proceedings

Following her ouster, respondent Sombrino filed a Complaint for Illegal Ejectment and Recovery of Possession before the Office of the Provincial Agrarian Reform Adjudication Board (DARAB docket X-543-LN-2005). The PARAD, in a Decision dated October 28, 2005, declared Crispina Sombrino a de jure tenant, ordered her reinstatement, and directed execution of an agricultural leasehold contract pursuant to administrative authorization. The PARAD found that Sombrino had been installed as tenant by the Sps. Romero in 1952 and that the leasehold relation bound successors in interest.

DARAB Proceedings

The petitioners Heirs of Lutero appealed to the Department of Agrarian Reform Adjudication Board (DARAB). In a Decision dated June 28, 2010, the DARAB denied the appeal and affirmed the PARAD, holding that an agricultural leasehold relation had been established and that Section 10 of RA 3844 preserved such relation against transfer of legal possession. The DARAB denied reconsideration by Resolution dated February 26, 2016.

Court of Appeals Proceedings

The petitioners Heirs of Lutero sought review in the Court of Appeals in CA-G.R. SP No. 07367-MIN. The CA, in the assailed Decision dated January 22, 2018, denied the petition for lack of merit and affirmed the DARAB and PARAD findings that substantial evidence established the essential elements of tenancy and that the petitioners were bound to respect the leasehold despite transfer of legal possession. The CA denied reconsideration in an assailed Resolution dated June 8, 2018.

Issue Presented

The dispositive issue was whether an agricultural leasehold tenancy relationship existed between the petitioners Heirs of Lutero and respondent Sombrino, i.e., whether respondent Sombrino was a de jure tenant entitled to security of tenure under agrarian laws.

Applicable Statutory and Doctrinal Law

The Court applied the test for agricultural leasehold tenancy under RA 1199, Sec. 4, as amended, and the protective provisions of RA 3844, including Sections 7 and 9 concerning security of tenure and binding effect upon heirs. Jurisprudence requires proof of six indispensable elements for tenancy: that the parties are landowner and tenant; that the subject matter is agricultural land; that both parties consented to the relationship; that the purpose was agricultural production; that the tenant personally cultivated the land; and that harvests were shared. The Court reiterated that tenancy is not presumed and that administrative certifications have limited evidentiary value.

Analysis and Findings of the Supreme Court

The Court held that the exceptions to the general rule barring factual review under Rule 45 applied because the lower adjudications rested on findings that were manifestly mistaken and based on misapprehension of facts. On the merits, the Court found that respondent Sombrino failed to prove the existence of an agricultural leasehold tenancy with the Sps. Romero. The Court reasoned that the documentary and testimonial proofs relied upon by PARAD and DARAB — including a joint affidavit of hired laborers, a barangay agrarian committee certification, and acknowledgment receipts for payments — were insufficient to establish the landowner's consent to a tenancy. The Court stressed precedent that mere occupation or cultivation does not convert a tiller into a de jure tenant and that certifications by barangay officials or administrative officers are provisional and must be corroborated. The Court further observed the incontrovertible fact, established in De Romero v. CA, that Eugenio died in 1948 and therefore could not have installed Sombrino as tenant in 1952. More fundamentally, the Court held that even if a tenancy agreement had been made with

Case Syllabus (G.R. No. 241353)

Parties and Procedural Posture

Danilo Romero, Victorio Romero and El Romero, representing their deceased father Lutero Romero, Petitioners filed a Petition for Review on Certiorari under Rule 45, Rules of Court assailing the decision and resolution of the Court of Appeals in CA-G.R. SP No. 07367-MIN.
Crispina Sombrino, Respondent defended the administrative findings that declared her a de jure tenant and sought to maintain possession of the subject landholding.
The case arose from a PARAD Decision dated October 28, 2005 that declared Respondent Sombrino a de jure tenant and ordered her reinstatement, which the DARAB affirmed in its Decision dated June 28, 2010.
The Court of Appeals denied the petition for review and affirmed the DARAB in its Decision dated January 22, 2018 and Resolution dated June 8, 2018, prompting the present Rule 45 petition to the Supreme Court.

Key Factual Allegations

The subject property comprised a two-hectare portion of Lot No. 23, Pls-35 at Marauding Annex, Kapatagan, Lanao del Norte, covered by Original Certificate of Title No. P-2261 in the name of Lutero Romero following a homestead patent approved in 1967.
Prior litigation in Civil Case Nos. 591 and 1056 culminated in a final and executory Supreme Court Decision in Teodora Saltiga de Romero, et al. v. Court of Appeals, et al. that adjudged Lutero Romero the true and lawful owner of the subject property.
Respondent Sombrino alleged she and her late husband were installed as tenants in 1952 by the purported original landowners, the spouses Eugenio and Teodora Romero, and she sought reinstatement after being ousted pursuant to execution of the final judgment favoring Lutero.
The RTC issued a Writ of Execution in 2003 and a Writ of Demolition in 2005, which resulted in Respondent Sombrino being dispossessed on April 5, 2005.
Respondent Sombrino presented a joint affidavit of hired workers, a BARC chairman’s affidavit, and acknowledgment receipts as evidence of tenancy.

Prior Litigation

The RTC rendered judgment in favor of Lutero Romero on March 11, 1991, nullifying alleged affidavits of sale and ordering surrender of possession to Lutero.
The Court of Appeals affirmed the RTC, and the Supreme Court in De Romero v. CA finally declared Lutero the rightful patentee and owner and held that Eugenio never owned the subject land.
After execution and dispossession, Respondent Sombrino filed a PARAD complaint docketed as DARAB Case No. X-543-LN-2005 seeking reinstatement and security of tenure.
The PARAD found Respondent Sombrino a de jure tenant on October 28, 2005, the DARAB affirmed on June 28, 2010, and the Court of Appeals dismissed the petition for review of the administrative decisions on January 22, 2018.

Issue

The principal issue was whether Respondent Sombrino was a de jure agricultural tenant entitled to security of tenure under agrarian tenancy laws as against the petitioners who derived title from Lutero Romero.

Ruling and Disposition

The Court granted the petition and held that Respondent Sombrino was not a de jure tenant and thus was not entitled to security of tenure.
The Court reversed and set aside the assailed Court of Appeals Decision dated January 22, 20