**Facts:**
This case traces its roots to the ejectment complaint filed by petitioner Renato Reyes against Leopoldo Barrios concerning a 3.6-hectare landholding in Mapaniqui, Candaba, Pampanga. Renato Reyes, co-owner with his sisters of a larger property under TCT No. 14488, argued that the said parcel was exempt from the Operation Land Transfer under Presidential Decree No. 27 (PD 27), viewing Barrios not as a tenant but as an overseer of a farm and piggery who failed to remit profits.
Leopoldo Barrios countered, claiming tenancy since 1972, improvements made on the property, and the management of the piggery business until its cessation. His failure to attend hearings due to health issues resulted in an ex-parte PARAD decision in 1996 favoring Reyes. Barrios appealed, but died during the process, leading to his substitution by his spouse Lucia Manalus-Barrios.
The DARAB reversed the PARAD decision in 1998, affirming Barrios’ bona fide tenancy, pointing to evidence such as a certification and attestations from neighbors. A 2004 DARAB Resolution further directed the issuance of an Emancipation Patent in Barrios’ favor, which was then modified to include the tenant’s surviving spouse due to Partos’ demise. Reyes’ motions for reconsideration were denied, prompting appeals to the Court of Appeals, which upheld the DARAB’s rulings, leading to the instant petition for review by the Supreme Court.
**Issues:**
1. Whether the Court of Appeals erred in affirming the DARAB rulings, thereby denying Reyes due process.
2. Whether Reyes’ claim to a retained area, purportedly awarded under a Land Bank claim, was adequately addressed.
**Court’s Decision:**
The Supreme Court partially granted the petition, affirming the finding of Barrios as a bona fide tenant based on substantial evidence but set aside the directive for issuing an Emancipation Patent. It highlighted that the procedural steps and required documents for an Emancipation Patent were not adequately followed or provided. Additionally, the Court noted the lack of sufficient evidence to prove Barrios’ full payment for the land and emphasized the exclusive jurisdiction of the DAR Secretary over retention area issues. Consequently, the 29 June 1998 DARAB Decision was reinstated, while the directives concerning the Emancipation Patent were annulled.
**Doctrine:**
The decision reinforced several significant legal principles:
1. The DARAB and its adjudicators are not bound by technical rules of procedure and evidence, aiming for a just, expedient, and equitable resolution.
2. Affidavits and other evidence may be admissible without strict adherence to the Rules of Court.
3. Issuance of an Emancipation Patent requires full compliance with procedural steps and documentation, along with full payment of the land.
**Class Notes:**
– **Key Elements for DARAB Proceedings:** Emphasis on justice and equity over technical procedures; substantial evidence as the benchmark; non-litigious nature.
– **Tenant Rights and Emancipation Patent Issuance:** Full compliance with PD 27 procedures and requirements is essential for an Emancipation Patent; bona fide tenancy supported by substantial evidence is protected.
– **Jurisdiction Issues:** The DAR Secretary’s exclusive jurisdiction over retention areas and the procedural pathway for issuing Emancipation Patents.
**Historical Background:**
The context of the case is deeply rooted in the Philippines’ agrarian reform efforts, particularly PD 27, which aimed to emancipate tenants from the “bondage of the soil” by transferring land ownership to them. This legal battle illustrates the complexities and challenges in implementing agrarian reform policies, including determining bona fide tenancy, adherence to legal procedures, and the rights of landowners versus tenants.
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