Dela Cruz v. People
REITERATIONFacts
The Antecedents: Claro Ignacio owned a three-hectare riceland leased to Valentin Sarmiento. Upon Valentin's death in 1981, his son Julian Sarmiento succeeded him as lessee. Claro Ignacio migrated to the U.S.A., and his daughter, petitioner Jessie dela Cruz, collected rent until 1991 when she refused to accept further payments. On May 28, 1996, Norberto de Guzman informed Sarmiento that someone had entered his land. Sarmiento found petitioner dela Cruz and Oscar Galvizo instructing laborers armed with bolos. Sarmiento reported the incident to the barangay captain. On May 31, 1996, Sarmiento filed a criminal complaint for violation of P.D. No. 583 against petitioner and a "John Doe." On June 3, 1996, Sarmiento filed a complaint with the DARAB against petitioner to restrain her from disturbing his possession. Petitioner filed a case against Sarmiento for declaratory relief, recovery of possession, etc. At the pre-trial of the civil suit, parties stipulated that Vicente Sarmiento (father of Julian) was a tenant, Julian cultivated the land after his father's death, and Julian delivered the owner's share, which petitioner refused to accept, leading to deposit in a bank. The criminal complaint before the MTC was dismissed for lack of jurisdiction. Sarmiento then filed a new case before the RTC for violation of P.D. No. 583, including Oscar Galvizo as accused. Procedural History: The RTC of Cauayan, Isabela, Branch 19, in Criminal Case No. Br. 19-1134, found petitioner Jessie dela Cruz and Oscar Galvizo guilty of violating P.D. No. 583, sentencing them to eight (8) years and one (1) day to ten (10) years of prision mayor. The Court of Appeals affirmed this judgment on August 7, 2000, in CA-G.R. CR No. 22637. A motion for reconsideration was denied on May 28, 2001. The Petition: Petitioner seeks reversal of the Court of Appeals' Decision and Resolution, alleging grave abuse of discretion in finding her guilty, in ruling that conspiracy existed, and in imposing the penalty.
Issue(s)
Whether the evidence is sufficient to prove petitioner's guilt beyond reasonable doubt for violation of P.D. No. 583. Whether there was sufficient proof to establish conspiracy between petitioner and Oscar Galvizo. Whether the penalty imposed by the Court of Appeals is correct.
Ruling
The petition is DENIED. The Decision dated August 7, 2000, of the Court of Appeals in CA-G.R. CR No. 22637, as well as its Resolution dated May 28, 2001, is AFFIRMED with the MODIFICATION that in lieu of imprisonment, JESSIE DELA CRUZ and OSCAR GALVIZO shall instead PAY a fine of P7,000.00 each.
Ratio Decidendi
On the sufficiency of evidence to prove guilt: The Court affirmed the conviction, holding that the leasehold relation between Julian Sarmiento and Claro Ignacio did not cease upon Valentin's death, and Julian, as the successor, was entitled to security of tenure under Section 7 of R.A. No. 3844. Petitioner's act of re-possessing the land on May 28, 1996, without a final and executory judgment from the DARAB authorizing dispossession, constituted a violation of Julian Sarmiento's right to security of tenure, making her liable under Section 4 of P.D. No. 583. The Court emphasized that the tenant's right to security of tenure cannot be prejudiced by any agreement limiting the period of tenancy or by the lessor's unilateral action, as dispossession requires a court judgment after due hearing. The alleged oral agreement and Sarmiento's non-payment of rentals did not justify petitioner's unauthorized re-entry, as non-payment only provides grounds for seeking eviction through legal means, not for self-help. The Court clarified that force, threat, or intimidation are not essential elements of the crime under Section 4 of P.D. No. 583; any act, scheme, or strategy contravening land reform laws is sufficient. The existence of a leasehold relationship, the fact of dispossession, and the absence of a final and executory judgment authorizing it are the elements to be proven. On the sufficiency of proof to establish conspiracy: The Court found sufficient evidence of conspiracy between petitioner and Galvizo. Prosecution witnesses Rey Galindez and Modesto Agpaoa corroborated Sarmiento's account, testifying that Galvizo was seen working on the land with petitioner's laborers and that both petitioner and Galvizo were present on the premises with other unidentified men when barangay officials investigated the incident. These testimonies convinced the Court that Galvizo and petitioner had planned the ejectment of Sarmiento, establishing them as co-conspirators. On the correctness of the penalty: The Court affirmed the penalty of imprisonment imposed by the lower courts as it conformed with Section 4 of P.D. No. 583. However, considering that petitioner and Galvizo had no prior convictions and to serve the ends of criminal justice by redeeming valuable human material and preventing unnecessary deprivation of liberty, the Court modified the penalty. In lieu of imprisonment, each was ordered to pay a fine of P7,000.00, citing the philosophy behind the Indeterminate Sentence Law and the pronouncement in Vaca v. Court of Appeals.
Main Doctrine
A landowner who unlawfully ejects a tenant-farmer without a final and executory court judgment authorizing dispossession violates the tenant's right to security of tenure and is liable under P.D. No. 583, even if the tenant has failed to pay rentals, as non-payment only entitles the lessor to seek eviction through proper legal channels, not to take the law into their own hands.