Dela Cruz v. Quiazon
REITERATIONFacts
The Antecedents: The underlying dispute concerns a parcel of land in Sto. Domingo II, Capas, Tarlac, originally owned by Estela Dizon-Garcia. Her daughter, respondent Amelia G. Quiazon, inherited the property. The land was covered by Operation Land Transfer under Presidential Decree No. 27, and a Certificate of Land Transfer (CLT) was issued to Feliciano dela Cruz, father of petitioners Ferdinand and Renato dela Cruz, for a 3.7200-hectare portion. Respondent later filed a complaint alleging that petitioner Ferdinand dela Cruz, who entered into a leasehold contract with her, failed to deliver rental payments and had abandoned the landholding. The complaint was amended to implead Feliciano and Renato dela Cruz, alleging that Ferdinand and Feliciano had migrated to the U.S.A., and that Renato was a usurper cultivating the land without the landowner's consent. Petitioners contended that their father's temporary absence did not constitute abandonment and that Renato's cultivation was in aid of his father's farming. Procedural History: The Provincial Adjudicator initially dismissed respondent's complaint, finding no abandonment by Feliciano dela Cruz due to Renato's cultivation. Respondent appealed this decision to the DAR Adjudication Board (DARAB). During the appeal, respondent and her siblings filed an Application for Retention with the DAR Regional Office, which was granted, allowing them to retain the property. The DARAB eventually dismissed respondent's appeal. Subsequently, respondent filed a Petition for Relief from Judgment, claiming she only learned of the DARAB's decision upon her return from the U.S.A. and that her counsel had died. The DARAB granted this petition, setting aside its previous decision, canceling Feliciano dela Cruz's CLT, and ordering the petitioners to vacate the land, citing the landowner's retention right and abandonment. Petitioners' motion for reconsideration was denied. They then appealed to the Court of Appeals (CA), which affirmed the DARAB's decision. Petitioners are now before the Supreme Court. The Petition: Petitioners seek review of the CA's decision affirming the DARAB's grant of the petition for relief from judgment. They argue that the relief should not have been granted due to respondent's inexcusable negligence in monitoring her case and the death of her counsel. They also contend that respondent lacked legal standing to file the petition for relief as she had waived her rights to the property. Furthermore, petitioners assert that their CLT signifies ownership, that they did not abandon the land, and that the DAR's retention order was void for lack of due process. They argue that the cancellation of the CLT and their ejectment are improper. The Supreme Court, in its petition for review on certiorari, questions the CA's affirmation of the DARAB's decision, particularly the grant of the petition for relief, the ruling on abandonment and lease rentals, and the reliance on the DAR retention case.
Issue(s)
Whether the DARAB erred in granting the petition for relief from judgment. Whether respondent had the legal standing to file the petition for relief from judgment. Whether petitioners abandoned the subject landholding. Whether the DARAB erred in canceling the Certificate of Land Transfer (CLT) and ordering the ejectment of petitioners. Whether the DAR Decision in the retention case was valid and binding on the petitioners.
Ruling
The petition is GRANTED. The January 19, 2006 Decision and March 21, 2006 Resolution of the Court of Appeals are REVERSED and SET ASIDE. Consequently, the February 7, 2001 DARAB Decision granting the petition for relief from judgment is SET ASIDE and the July 7, 1999 DARAB Decision is REINSTATED.
Ratio Decidendi
On the grant of the petition for relief from judgment: The Supreme Court held that a petition for relief from judgment is an equitable remedy available only in exceptional cases and requires a showing of fraud, accident, mistake, or excusable negligence. In this case, respondent's failure to file a motion for reconsideration or appeal was due to her inexcusable negligence. The Court noted that respondent herself received a copy of the DARAB decision and had engaged a new counsel in another case as early as 1995, contradicting her claim of ignorance regarding her former counsel's death and the status of her case. Allowing such a petition based on inexcusable negligence would revive the lost right to appeal due to negligence, which is contrary to the purpose of the remedy. The Court emphasized that parties must be assiduous in monitoring the status of their litigation, and respondent's inaction for almost five years demonstrated a total lack of vigilance. On respondent's legal standing: The Supreme Court sustained respondent's personality to file the petition for relief from judgment. The Court explained that a petition for relief is available to a party to the principal case, and this legal standing is not lost by the mere transfer of the disputed property pendente lite. The original party retains their personality as a real party-in-interest despite the transfer of interest during the pendency of the litigation. On abandonment of the landholding: The Supreme Court agreed with the petitioners that they had not abandoned the subject landholding. The Court defined abandonment as requiring a clear and absolute intention to renounce a right or property, coupled with an external act expressing that intention. The immigration of the original farmer-beneficiary to the U.S.A. did not automatically constitute abandonment, especially since his son, petitioner Renato dela Cruz, continued to cultivate the land. Personal cultivation includes cultivation with the aid of the immediate farm household, which encompasses family members who usually help in agricultural activities. Therefore, the finding of abandonment by the DARAB was erroneous. On the cancellation of the CLT and ejectment: The Court ruled that the DARAB erred in canceling the petitioners' CLT and ordering their ejectment based on a finding of abandonment. While the issuance of a CLT does not vest full ownership, it signifies qualification for ownership acquisition under P.D. No. 27. The landowner retains an interest that allows for eviction in case of abandonment. However, the cancellation of a CLT as a consequence of a landowner's exercise of the right of retention is within the administrative jurisdiction of the DAR Secretary, not the DARAB, as it does not involve an agrarian dispute. The DARAB's jurisdiction over CLT matters is limited to cases with an agrarian dispute. On the validity of the DAR retention order: The Supreme Court noted that the validity of the DAR Order granting the application for retention, particularly concerning the petitioners' claim of denial of due process, should be raised before the DAR Secretary. The Court stated that a collateral attack against a judgment is generally not allowed unless the judgment is void on its face. However, the Court also reminded respondent that even if the CLT is canceled, petitioners may not be ejected if they choose to remain as beneficiaries in the same or another agricultural land with similar features, as per Section 6 of R.A. No. 6657.
Main Doctrine
The Supreme Court held that a petition for relief from judgment due to the death of counsel is only available in exceptional cases and requires a showing of excusable negligence, not mere inexcusable negligence. Furthermore, the Court clarified that the issuance of a Certificate of Land Transfer (CLT) does not vest full ownership in the farmer-beneficiary, and the landowner retains an interest that allows for actions to evict the tenant in case of abandonment. However, abandonment requires a clear intention to renounce the right and an external act expressing it, and immigration to the U.S.A. does not automatically constitute abandonment if the land is still cultivated by a family member. The cancellation of a CLT as a consequence of a landowner's exercise of the right of retention falls under the administrative jurisdiction of the DAR Secretary, not the DARAB, especially when there is no agrarian dispute.