Greenfield Realty Corporation v. Cardama
REITERATIONFacts
The Antecedents: Private respondents (Loreto Cardama, et al.) filed a complaint with the Provincial Adjudicator of the Department of Agrarian Reform (DAR) Region IV, seeking to be declared as bonafide tenants of Lot No. 2653 and legitimate beneficiaries of the Comprehensive Agrarian Reform Law (CARL). They claimed to have succeeded their deceased father, Hermogenes Cardama, in his tenancy rights, which allegedly began in 1978 through a verbal agreement with Independent Realty Corporation (IRC). They asserted that they cleared and developed the land, constructing irrigation canals at their own expense, and had been paying lease rentals. Procedural History: The Provincial Adjudicator ruled in favor of the private respondents, declaring them as leasehold tenants and directing the cancellation of Certificates of Land Transfer of intervenors and disqualifying PANALAG members. The DARAB, on appeal, reversed this decision, declaring Hermogenes Cardama not a bona fide tenant and transmitting the records to the DAR Secretary for further proceedings. The Court of Appeals, in turn, reinstated the Provincial Adjudicator's decision, declaring the private respondents as tenants and ordering the surrender of possession to them. The Petition: Petitioners Greenfield Realty Corporation and Data Processing Services Corporation filed a petition for review, arguing that the Court of Appeals erred in reversing the DARAB's findings of fact, in not dismissing the case for forum-shopping, and in ruling that res judicata had not set in.
Issue(s)
Whether the Court of Appeals erred in reversing the findings of fact of the DARAB. Whether the private respondents were guilty of forum-shopping. Whether the doctrine of res judicata barred the institution of the DARAB case.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed, reinstating the decision of the Provincial Adjudicator which declared the private respondents as tenants of Lot No. 2653 and directing the surrender of possession to them.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in reversing the findings of fact of the DARAB: The Supreme Court held that the Court of Appeals did not err. It clarified that the findings of fact of the DAR are final and conclusive only if based on substantial evidence, as provided by Section 54 of Republic Act No. 6657. The Court found that the DARAB's conclusion that Hermogenes Cardama was not a bona fide tenant was not based on substantial evidence. The DARAB's reliance on the existence of Certificates of Land Transfer (CLTs) issued in 1981 and the alleged location of rental payments in a different barangay (Bungahan) was deemed not adequate to negate the tenancy claim. The Court noted that Hermogenes Cardama could have become a tenant in 1981, and rental receipts mentioning 'Bungahan' did not necessarily exclude Lot 2653 in 'Loma'. Conversely, the Court found substantial evidence supporting the tenancy claim, including a Joint Report and a letter from Greenfield Development Corporation dated January 19, 1989, acknowledging Hermogenes Cardama as its tenant for various lots, including Lot 2653, and collecting unpaid rentals. The Court also considered the fact that the land was cultivated by Hermogenes Cardama with other tenants, who were related to him, and that the landholding exceeded what one person could cultivate alone, suggesting their entitlement was in their individual capacity as tenants. On the issue of forum-shopping: The Supreme Court found no forum-shopping. The private respondents sufficiently explained that the petition before the Court of Appeals was based on tenancy rights and rights under the CARL, focusing on entitlement to benefits and protection. In contrast, the case pending before the Regional Trial Court of Biñan was for injunction to prevent the use of force and intimidation to eject lawful possessors without a final and executory decision. Therefore, the issues involved in both cases were different, and the Court of Appeals correctly ruled that no forum-shopping occurred. On the issue of res judicata: The Supreme Court found the petitioners' contention untenable. The prior case, CAR Case No. B-26, was dismissed based on a compromise agreement where both counsels manifested an understanding regarding the possession of the land. However, the dismissal order did not specify the terms of the compromise. The Court noted that while a judgment upon a compromise has the effect of res judicata, any cause of action arising from the application or violation of the compromise agreement cannot be considered settled in the first case. The institution of DARAB Case No. IV-0272'93 was deemed to have arisen from a violation of the compromise agreement, thus not barred by res judicata.
Main Doctrine
The Court of Appeals did not err in reversing the findings of fact of the DARAB when such findings were not based on substantial evidence. Substantial evidence requires relevant evidence that a reasonable mind would accept as adequate to support a conclusion, considering all the evidence presented and reasonable inferences therefrom.