Dela Cruz v. Cailles
REITERATIONFacts
The Antecedents: Respondent Jesusa Y. Cailles (Cailles) owned a parcel of land in Gapan City, which was under an agricultural leasehold with the Dela Cruzes (Petitioners). On June 29, 2006, the Dela Cruzes executed a notarized 'Sinumpaang Salaysay' (Voluntary Surrender) in favor of Carlito Adel (Carlito), transferring their possession and tilling rights. Cailles subsequently alleged that Carlito converted part of the land into a fishpond and built a house without consent. However, evidence showed that by December 4, 2007—less than two years after the deed—Carlito returned the management of the land to the Dela Cruzes after they settled a loan. Throughout this period and thereafter, Cailles' representative, Alicia Y. Yacat (Yacat), continued to accept lease rentals from the Dela Cruzes and issued receipts in their names. Procedural History: Cailles filed a complaint for recovery of possession before the Provincial Agrarian Reform Adjudication Board (PARAD), which ordered the eviction of the Dela Cruzes on the ground of abandonment. On appeal, the Department of Agrarian Reform Adjudication Board (DARAB) reversed the PARAD, ruling that there was no clear intent to abandon since the Dela Cruzes remained in active cultivation and the landowner accepted their rentals. The Court of Appeals (CA) then reversed the DARAB and reinstated the PARAD ruling, holding that the notarized 'Sinumpaang Salaysay' was entitled to full faith and credit as proof of voluntary surrender. The Petition: The Dela Cruzes filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court. They argued that the CA erred in prioritizing the literal text of the surrender deed over the factual reality of their continuous cultivation. They maintained that they were uneducated and were deceived into signing the deed, believing it was merely a loan document, and emphasized that the landowner's acceptance of rentals after the deed's execution proved the continuation of the leasehold relationship.
Issue(s)
Whether the Court of Appeals erred in ruling that the execution of a notarized 'Sinumpaang Salaysay' (Voluntary Surrender) was sufficient to establish abandonment and terminate the agricultural leasehold relationship, considering the requirements of Republic Act No. 3844 (RA 3844), the doctrine in Corpuz v. Grospe, the evidence of continued cultivation, and the acceptance of lease rentals.
Ruling
The Petition is GRANTED. The Decision and Resolution of the Court of Appeals are REVERSED and SET ASIDE. The Complaint for recovery of possession is DISMISSED.
Ratio Decidendi
On the Issue of Abandonment: The Supreme Court held that the Court of Appeals (CA) erred in finding abandonment based solely on the notarized deed. While a notarized document is generally entitled to full faith and credit, it cannot override the substantive requirements of Republic Act No. 3844 (RA 3844) for the extinguishment of a leasehold. The Court emphasized that abandonment requires a clear and absolute intention to renounce a right, coupled with an external act of desertion. Applying the doctrine in Corpuz v. Grospe, the Court noted that abandonment is only established if there is a failure to cultivate the land for at least two calendar years. In this case, the evidence showed that Carlito returned possession to the Dela Cruzes in December 2007, less than two years after the 2006 deed was executed. Furthermore, the Dela Cruzes' continued physical cultivation was corroborated by neighboring farmers. Most significantly, the Court found that the respondent's representative, Yacat, accepted lease rentals and issued receipts in the petitioners' names even after the execution of the surrender deed. This acceptance of rentals effectively estopped the respondent from claiming abandonment and constituted a ratification of the petitioners' continued status as agricultural lessees. Consequently, the contemporaneous acts of the parties negated the claim of an irrevocable intent to abandon the landholding.
Main Doctrine
To justify the extinguishment of an agricultural leasehold relation through abandonment under Republic Act No. 3844 (RA 3844), the landowner must prove a deliberate and clear intent to depart with the avowed purpose of never returning. This intent must be exhibited by a factual failure or refusal to work on the landholding without a valid reason for at least two calendar years. If the tenant resumes possession or continues cultivation and the landlord accepts rentals within that two-year window, the claim of abandonment fails as the essential element of irrevocable intent is absent.