Villanueva v. Yap
REITERATIONFacts
The Antecedents: Respondent Generoso Yap filed a complaint (Civil Case No. 3551) against petitioner Lina Villanueva for recovery of possession of two parcels of land, alleging he purchased them from Concepcion G. Malonjao and that Villanueva occupied the property without color of title. Villanueva claimed she was appointed caretaker in 1974, later designated as timekeeper and capataz in 1978, and filed a labor case against Malonjao for illegal dismissal after her services were terminated. The RTC dismissed Yap's complaint and awarded damages to Villanueva on her counterclaims. Both parties appealed, and the Court of Appeals affirmed the RTC decision. This decision became final and executory. Procedural History: While the first case was pending appeal, Yap filed another complaint (Civil Case No. 4825) against Villanueva for recovery of possession of the same property, plus an additional lot. Villanueva moved to dismiss based on res judicata, but the motion was denied. The RTC ruled in favor of Yap, ordering Villanueva to vacate and pay damages. Villanueva appealed, arguing res judicata, lack of jurisdiction (claiming DARAB had jurisdiction due to tenancy), and error in finding her in bad faith. The Court of Appeals affirmed the RTC decision. Villanueva then filed a petition to annul the RTC decision in Civil Case No. 4825 with the Court of Appeals, which was dismissed and became final. She also filed a motion to stay execution in Civil Case No. 4825, which was denied. The Sheriff reported partial enforcement of the decision, with Villanueva evicted but unable to pay damages due to poverty. The Petition: Villanueva filed a petition for certiorari with the Supreme Court, seeking to annul the RTC decision in Civil Case No. 4825, arguing that the DARAB, not the RTC, had jurisdiction. She also contended that the action was barred by res judicata from Civil Case No. 3551 and that she and Yap had a tenancy relationship. The Supreme Court issued a temporary restraining order.
Issue(s)
Whether the action for recovery of possession in Civil Case No. 4825 was barred by res judicata, and whether the Regional Trial Court (RTC) had jurisdiction over the subject matter, or if it falls under the jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB). Whether a tenancy relationship existed between the petitioner and the respondent. Whether the petition for certiorari under Rule 65 was the proper remedy, considering the finality of the Court of Appeals' decision affirming the RTC ruling in Civil Case No. 4825 and the lapse of the reglementary period for appeal.
Ruling
The petition is denied due course and dismissed for utter lack of merit. The decision of the Court of Appeals affirming the RTC decision in Civil Case No. 4825 has become final and executory and is beyond review. The petition was filed beyond the reglementary period for filing a petition for review on certiorari, and it constitutes a futile attempt to relitigate issues already settled by final judgments.
Ratio Decidendi
On the issue of res judicata and jurisdiction: The Supreme Court noted that the Court of Appeals, in affirming the RTC decision in Civil Case No. 4825, had already considered the issue of res judicata. The appellate court, while acknowledging that the first case could operate as a bar, chose not to rigidly apply the rule of res judicata to prevent a denial of substantial justice, citing several Supreme Court precedents. The Court emphasized that technical rules should not be used to sacrifice justice for technicality. Furthermore, the Court found that the petitioner's own admissions in Civil Case No. 3551, where she claimed to be an employee (timekeeper and capataz) and filed a labor case for illegal dismissal, contradicted her later claim of being a tenant. The Court reiterated the requisites for a tenancy relationship, including sharing of harvests, which was absent in this case due to a "growership agreement" between the former owner and STANFILCO. The Court also noted that the land was less than three hectares, placing it outside the purview of Republic Act No. 6657 (Comprehensive Agrarian Reform Law). Consequently, the Court held that the DARAB did not have jurisdiction, and the RTC did not err in taking cognizance of the case. The Court also found no basis for the petitioner's claim of good faith. Her admissions of being an employee and filing a labor case contradicted her subsequent claim of being a tenant. Agricultural employees do not possess tenurial rights over the land they cultivate. The findings in Civil Case No. 3551, which incidentally touched upon the issue of tenancy, were not conclusive and could not be the basis for a defense of good faith, especially since res judicata was not applied to that specific finding in the subsequent case. The Court reiterated that the petitioner was aware of her status as an employee, not a tenant, and therefore could not claim good faith in continuing to occupy the property. On the existence of a tenancy relationship: The Supreme Court affirmed the Court of Appeals' finding that no tenancy relationship existed. The petitioner's own answer in Civil Case No. 3551 admitted allegations that she was employed as a timekeeper and "capataz" by Concepcion Malonjao and that she filed a labor case for illegal dismissal. The Court highlighted that for tenancy to exist, several requisites must concur, including consent, purpose of agricultural production, personal cultivation, and sharing of harvests. The petitioner failed to establish all these requisites. Specifically, the existence of a "growership agreement" negated the possibility of crop sharing between the landowner and the petitioner. The Court also pointed out that the land was less than three hectares, which is not within the purview of RA 6657. On the propriety of the petition for certiorari and the finality of judgments: The Supreme Court emphasized that the petition for certiorari under Rule 65 was not the proper remedy. The decision of the Court of Appeals in CA-G.R. CV No. 48126, which affirmed the RTC decision in Civil Case No. 4825, had become final and executory. The Supreme Court stated that it is bereft of jurisdiction to annul a final and executory decision of the Court of Appeals. The Court also noted that the petition was filed on November 20, 2000, long after the lapse of the fifteen-day reglementary period for filing a petition for review on certiorari under Rule 45, which expired sometime in 1994 or 1995 based on the RTC decision date. Furthermore, the petitioner had previously filed a petition to annul the same judgment with the Court of Appeals (CA-G.R. SP No. 60812), which was dismissed and became final. The present petition was deemed a futile attempt to relitigate settled issues.
Main Doctrine
A petition for certiorari under Rule 65 is not a substitute for a lost appeal and cannot be used to annul a final and executory decision of the Court of Appeals.