Perez-Rosario v. Court of Appeals
REITERATIONFacts
The Antecedents: This case concerns a dispute over an agricultural landholding of approximately 2.2277 hectares in Barangay Obong, Basista, Pangasinan, registered under Nicolasa Tamondong Vda. de Perez. The core of the dispute involves the cultivation and tenancy rights over this land, which is used for rice and mango production. The original owner sold the property with a right to repurchase to Miguel Resultay, who then cultivated the land. Subsequently, the property was repurchased by the heirs of Nicolasa Tamondong Vda. de Perez, the petitioners herein. The conflict escalated when the petitioners filed an ejectment case against the respondents, alleging non-payment of lease rentals and unauthorized sub-leasing. Procedural History: The ejectment case was initially filed with the Department of Agrarian Reform Adjudication Board (DARAB). The Provincial Agrarian Reform Adjudicator ruled in favor of the petitioners, ordering the dispossession of some respondents and maintaining others. However, upon appeal, the DARAB reversed this decision, declaring the respondents as agricultural tenants and maintaining Basilio Cayabyab in possession as an agricultural lessee. The DARAB's decision was later affirmed in toto by the Court of Appeals (CA). The petitioners sought reconsideration from the CA, which was denied. Consequently, the petitioners filed a Petition for Certiorari under Rule 65 of the Rules of Court with the Supreme Court, challenging the CA's decision. The Petition: The petitioners filed a Petition for Certiorari under Rule 65 of the Rules of Court, arguing that the Court of Appeals and the DARAB committed gross error and grave abuse of discretion in declaring private respondents Mercedes Resultay and Basilio Cayabyab as agricultural lessees. They contended that these declarations were contrary to established facts, evidence, law, and jurisprudence. The petitioners specifically questioned the findings regarding personal cultivation, the alleged sub-leasing, and the payment of lease rentals. The Supreme Court, however, found that a petition for review on certiorari under Rule 45 was the proper remedy and that the petitioners' choice of certiorari under Rule 65 was a procedural error. Nevertheless, the Court proceeded to review the merits and found no reversible error in the decisions of the lower courts.
Issue(s)
Whether the Court of Appeals and DARAB erred in declaring private respondents Mercedes Resultay and Basilio Cayabyab as agricultural lessees; and whether the declarations of private respondents as agricultural lessees are contrary to established facts, adduced evidence, law, and jurisprudence. Whether the public respondents committed grave abuse of discretion in declaring private respondents as agricultural lessees. Whether the procedural issue of filing a petition for certiorari is proper; and on the issue of sub-leasing and payment of lease rentals; and on the conversion from share tenancy to leasehold.
Ruling
The petition is DENIED. The assailed Decision and Resolution of the Court of Appeals are AFFIRMED.
Ratio Decidendi
On the substantive issues of agricultural leasehold and personal cultivation: Even if the procedural lapse were excused, the petition would still fail on the merits. The Court reiterated that findings of fact by agrarian courts, such as the DARAB, when supported by substantial evidence, are conclusive and binding on appellate courts. The determination of personal cultivation is a factual issue not subject to review in a certiorari proceeding. Petitioners failed to discharge their burden of proving that the respondents did not personally cultivate the land. The hiring of farm laborers for occasional or temporary tasks, such as specific phases of farm work, does not negate the element of personal cultivation required for an agricultural leasehold relationship, provided the tenant does not entrust the entire cultivation to hired hands. This point is intentionally left blank as the previous ratio point sufficiently addresses the issue. On the procedural issue of filing a petition for certiorari; on the issue of sub-leasing and payment of lease rentals; and on the conversion from share tenancy to leasehold: The Court held that a petition for certiorari under Rule 65 is not a proper remedy when an appeal under Rule 45 was available and timely. Petitioners failed to file an appeal within the reglementary period after receiving the CA Resolution denying their motion for reconsideration. They cannot use a special civil action of certiorari to cure the loss of their right to ordinary appeal due to their own neglect or error in choosing the remedy. This procedural misstep warrants the dismissal of the petition. The Court affirmed the findings of the CA and DARAB that Basilio Cayabyab was a bona fide agricultural lessee and had duly paid his lease rentals. Evidence showed that Cayabyab made timely payments or deposits of rentals, and petitioners had received these payments, even if sometimes with delay or after withdrawal of deposited amounts with leave of court. The Court noted that the petitioners' refusal to promptly accept tender of lease rentals contributed to any confusion in accounting. The Court also found no conscious intent by Cayabyab to unlawfully deprive the landholders of their share, as evidenced by his consistent payment of rentals. The initial contract of lease between Miguel Resultay and Cayabyab, predating the petitioners' repurchase of the land, was deemed to have been assumed by the petitioners through subrogation. The Court noted that the juridical relationship appeared to be governed by agricultural share tenancy, which is outlawed by law and contrary to public policy. Therefore, it should be converted to an agricultural leasehold system in accordance with Republic Act No. 3844, as amended by Republic Act No. 6389. The lease rental should be determined according to pertinent laws and regulations.
Main Doctrine
A petition for certiorari under Rule 65 is not a substitute for a lost appeal under Rule 45. Furthermore, findings of fact by agrarian courts, when supported by substantial evidence, are conclusive on appellate courts. The hiring of farm laborers for occasional tasks does not negate the element of personal cultivation required for an agricultural leasehold relationship.