Natividad v. Mariano
REITERATIONFacts
The Antecedents: Petitioner Ernesto L. Natividad (Ernesto) purchased a 66,997 square meter agricultural land in Gapan, Nueva Ecija, in a public auction held on July 17, 1988. Respondents Fernando Mariano, Andres Mariano, and Doroteo Garcia were the tenants of the land. Ernesto alleged that he verbally demanded payment of lease rentals immediately after his purchase, but the respondents refused to pay, prompting him to demand they vacate. Procedural History: Ernesto filed a petition for ejectment and collection of back lease rentals with the Provincial Agrarian Reform Adjudication (PARAD) of Nueva Ecija. The respondents failed to file an answer, and the PARAD ruled in favor of Ernesto, ordering them to vacate and pay back rentals. This decision became final and executory. Subsequently, the respondents filed two Petitions for Relief from Judgment, citing excusable negligence, lack of knowledge of agrarian reform laws, indigence, and belated discovery of land valuation reports. The PARAD denied both petitions. The respondents appealed to the Department of Agrarian Reform Adjudication Board (DARAB), which reversed the PARAD's decision, ordering Ernesto to maintain the respondents' possession and ordering the respondents to pay back rentals as computed by the Municipal Agrarian Reform Officer (MARO). The Court of Appeals (CA) affirmed the DARAB's decision. The Petition: Ernesto filed a petition for review on certiorari with the Supreme Court, challenging the CA's findings that he failed to prove non-payment of lease rentals, that the respondents were excused from paying due to lack of knowledge of his acquisition, and that the final PARAD decision could be reopened.
Issue(s)
Whether the DARAB and CA erred in reopening a final and executory decision of the PARAD. Whether Ernesto sufficiently proved that the respondents failed to pay lease rentals. Whether the respondents' failure to pay lease rentals, if any, was willful and deliberate. Whether the payments made by the respondents to Corazon and Laureano Quiambao were valid. Whether the respondents' Certificates of Land Transfer (CLTs) affect the ejectment proceedings.
Ruling
The Supreme Court denied the petition, affirming the decision of the Court of Appeals with modification. The Court ordered Ernesto to immediately surrender possession of the subject property to the respondents and directed the DARAB to ensure the immediate restoration of possession to the respondents. The case was remanded to the Department of Agrarian Reform for the proper determination of the manner and mode of payment of the full value of the land to Ernesto and for the determination of the successor-in-interest of Diego Mariano to the landholding covered by his CLT.
Ratio Decidendi
On the reopening of the final and executory decision: The Court held that while the doctrine of immutability of judgments is well-settled, it is not absolute. In this case, the respondents' excusable negligence and indigence, stemming from their inexperience and lack of knowledge of agrarian reform laws and procedures, constituted justifiable grounds for relief. The DARAB and CA did not err in reopening the case to serve the broader interests of justice and equity, as the PARAD gravely abused its discretion in denying the petition for relief. The Court emphasized that procedural rules are intended to promote substantial justice and can be suspended when their rigid application would frustrate justice. On the sufficiency of proof of non-payment of lease rentals: The Court ruled that Ernesto failed to sufficiently prove that the respondents did not pay the lease rentals. Ernesto did not present any evidence, such as an affidavit, to support his claim that he made verbal demands for payment prior to filing the ejectment petition. Therefore, his claim of prior demands was unsubstantiated, and the respondents could not be deemed in delay until the filing of the petition. The Court reiterated the principle that he who alleges a fact has the burden of proving it, and mere allegations are not evidence. On whether the failure to pay was willful and deliberate: The Court found that even if there was a failure to pay, it was not willful and deliberate, which is a requirement for ejectment under Section 36 of R.A. No. 3844. The alleged non-payment did not last for the required two-year period. Moreover, the existence of rental payment receipts for the years 1988-1998 indicated that the non-payment was not absolute. The Court clarified that mere failure to pay does not automatically warrant ejectment; there must be a deliberate intent to withhold payment. On the validity of payments to Corazon and Laureano Quiambao: The Court affirmed the validity of the payments made by the respondents to Corazon and Laureano Quiambao. Ernesto purchased the property in 1988 but only demanded payment in 1998. During this ten-year period, the respondents consistently paid the lease rentals to Corazon and Laureano. The Court reasoned that Ernesto's prolonged inaction in demanding payment or asserting his right to receive rentals led the respondents to believe that Corazon and Laureano were still the authorized payees. Ernesto never repudiated their authority to receive payments. On the import of the respondents' Certificates of Land Transfer (CLTs): The Court recognized that the CLTs issued to Diego Mariano and Doroteo Garcia established their rights over the property and that they were deemed owners under Presidential Decree (P.D.) No. 27, subject to conditions. The Court held that the transfer or waiver of landholdings acquired under P.D. No. 27 is prohibited, except by hereditary succession or to the government. Therefore, Ernesto's purchase of the property via an execution sale could not defeat the rights of the CLT holders. The DARAB's reversal of the PARAD's decision, which ordered the respondents to surrender possession, was correct as it contravened the objectives of agrarian reform laws. The case was remanded to the DAR for proper determination of compensation to Ernesto and the successor-in-interest to Diego Mariano's CLT.
Main Doctrine
The DARAB and CA did not err in reopening a final and executory decision based on the respondents' excusable negligence and indigence, as procedural rules are intended to promote substantial justice and not to defeat it. Furthermore, the landowner bears the burden of proving non-payment of lease rentals, and such non-payment must be willful and deliberate for at least two years to warrant ejectment.