Lercana v. Jalandoni
REITERATIONFacts
The Antecedents: Gregorio Pajuelas owned a 19-hectare agricultural land. His daughter, Bruna Saberon, mortgaged it. Rodolfo Aspilla redeemed the land and hired laborers, including respondent Porferio Jalandoni, to work on it, initially planting sugarcane and later corn and auxiliary crops. Respondents gave Aspilla his share on a "tercio" basis. Aspilla mortgaged the property to Philippine Veterans Bank (PVB) in 1972, which was foreclosed in 1978, with title consolidating under PVB in 1980. Respondents continued to give Aspilla his share until 1984, and thereafter to his children. In August 1989, petitioner Lolihala S. Lercana appeared, claiming to have bought the land from PVB, and demanded the owner's share from the respondents. Petitioner and her relatives eventually took over and cultivated the land. Procedural History: Respondents filed a complaint for reinstatement and damages before the Department of Agrarian Reform Provincial Adjudication Board (PARAD), which dismissed their complaint, declaring them not tenants and not entitled to reinstatement. Respondents appealed to the Department of Agrarian Reform Adjudication Board (DARAB), which reversed the PARAD decision, declaring respondents as de jure agricultural tenants and ordering petitioner to vacate and reinstate respondents, but deleted the award of exemplary damages. The Court of Appeals affirmed the DARAB decision, modifying it by deleting the award of exemplary damages. Petitioner filed a motion for reconsideration, which was denied, leading to the present petition. The Petition: Petitioner seeks to reverse the Court of Appeals' decision, raising issues concerning her and her relatives' occupation and tillage over the eastern portion of the landholding and their qualification as beneficiaries under the Comprehensive Agrarian Reform Program (CARP). Petitioner argues that the Court of Appeals' factual findings conflict with the evidence on record and the trial court's (PARAD) findings.
Issue(s)
Whether petitioner and her relatives, as heirs of Gregorio Pajuelas, have proven by adequate or sufficient evidence their occupation and tillage over the eastern portion of the subject landholding. Whether petitioner and her relatives have shown sufficient evidence as beneficiaries of the subject landholdings in accordance with the provisions of the Comprehensive Agrarian Reform Law (CARL).
Ruling
The Supreme Court denied the petition for review for lack of merit and affirmed the decision of the Court of Appeals. The Court held that the findings of fact of the Court of Appeals, which affirmed those of the DARAB, that respondents were the tenants of the entire property, were supported by the evidence on record. The Court also ruled that the determination of CARP beneficiaries is an administrative matter exclusively within the jurisdiction of the Secretary of the Department of Agrarian Reform.
Ratio Decidendi
On the issue of occupation and tillage over the eastern portion of the landholding: The Court affirmed the Court of Appeals' finding, which adopted the DARAB's conclusion, that the respondents were the tenants of the entire property. This finding was supported by the testimony of petitioner's own witness, Galoy Ezoy, who stated that the property was worked by Aspilla and that petitioner and her relatives only started working on the land when the case was filed. Furthermore, certifications from the Barangay Agrarian Reform Committee (BARC) Chairman and Municipal Agrarian Reform Officer indicated that petitioner and her relatives were not the actual occupants and tillers and only took over the property by force and threats in 1990. The Court found that Sheriff Edwin L. Badon's certification, cited by petitioner, only attested to the cultivation and occupation during the pendency of the case, not from the time of alleged continuous occupation. Therefore, the evidence on record sufficiently supported the appellate court's conclusion that respondents were the tenants of the entire landholding. On the issue of qualification as beneficiaries under CARP: The Court held that the determination of beneficiaries under the Comprehensive Agrarian Reform Program (CARP) is an administrative matter exclusively cognizable by the Secretary of the Department of Agrarian Reform. The DARAB, in its decision, left this determination to the concerned DAR Offices. The Court reiterated that this matter is beyond the jurisdiction of the DARAB and, consequently, not an issue properly before the Supreme Court for resolution. Thus, the petitioner must pursue this matter through the appropriate administrative channels within the Department of Agrarian Reform.
Main Doctrine
The findings of fact of the Court of Appeals, when supported by substantial evidence, are final and conclusive, and the Supreme Court will not disturb them, especially when they affirm the findings of the Department of Agrarian Reform Adjudication Board (DARAB). The determination of CARP beneficiaries is an administrative matter exclusively cognizable by the Secretary of the Department of Agrarian Reform.