EUGENIO R. REYES, JOINED BY TIMOTHY JOSEPH M. REYES, MA. GRACIA S. REYES, ROMAN GABRIEL M. REYES, AND MA. ANGELA S. REYES, PETITIONERS, VS. LIBRADA F. MAURICIO AND LEONIDA F. MA…

Reyes versus Mauricio

The Case

This is a petition for review brought by Eugenio Reyes, joined by his children, against Librada Mauricio and Leonida Mauricio, seeking to overturn the rulings of the Department of Agrarian Reform Adjudication Board. The respondents had sued for annulment of a contract called a kasunduan and for maintenance of peaceful possession of an agricultural landholding in Bocaue, Bulacan. The case matters because it settles two questions every agrarian law examinee must know: how a tenancy relationship is proved and preserved, and whether the agrarian adjudicator may annul a document that the parties used to dissolve that tenancy.

Procedural History

The respondents filed their complaint for annulment of contract and maintenance of peaceful possession with damages before the Provincial Agrarian Reform Adjudicator for the province of Bulacan. The Provincial Adjudicator ruled in favor of Librada Mauricio, declaring the kasunduan null and void, ordering Reyes to respect her peaceful possession, and ordering her to return the amount of 50,000 pesos to Reyes. Reyes appealed to the Department of Agrarian Reform Adjudication Board, which affirmed the decision and later denied his motion for reconsideration. Reyes then came to the Supreme Court by petition for review under Rule 43 of the 1997 Rules of Civil Procedure.

Facts

Godofredo Mauricio had worked on the landholding in Turo, Bocaue, Bulacan, consisting of 4,527 square meters more or less, from 1936 until his death in May 1994, as a tenant of Reyes and his predecessors in interest. He introduced improvements, including fruit bearing trees, seasonal crops, and a house. The Municipal Agrarian Reform Officer testified that Godofredo was the bona fide tenant, and the Barangay Agrarian Reform Council president certified the same.

On September 28, 1994, after Godofredo's death, a document entitled kasunduan was prepared and notarized in Pasig, Metro Manila. Librada Mauricio affixed her thumbmark on it and received 50,000 pesos from Reyes on the same day. She later claimed she does not know how to read and write, that the contents were not explained to her, and that she never appeared before the notary public. Reyes countered that she chose to affix her thumbmark because she had difficulty writing, that she was accompanied by a relative, and that she was in full command of her mental faculties and was not coerced.

Reyes also denied that Godofredo was his tenant, claiming he merely tolerated Godofredo's occupation, and that his transfer certificate of title was clean and bore no annotation of any tenancy. The Provincial Adjudicator found that Godofredo was a bona fide tenant, that Leonida was not the daughter of Godofredo and Librada, and declared the kasunduan void. During the pendency of the case before the Supreme Court, Librada died, and Leonida, as her daughter, was allowed to substitute for her.

Issues

• Whether or not there was a valid and existing tenancy relationship between the parties.
• Whether or not the Department of Agrarian Reform Adjudication Board exceeded its jurisdiction in affirming the annulment of the kasunduan dated September 28, 1994.

Applicable Provisions

Republic Act Number 3844, the Agricultural Land Reform Code, governs the succession of a tenant's heirs to the tenancy relation. The Court applied it when it held that Godofredo was succeeded by his heirs in his tenancy relation with Reyes:

By operation of law (RA 3844), Godofredo is succeeded by his heirs in his tenancy relation with petitioner.

This provision bears on the case because it explains why Librada and Leonida, as wife and daughter, could maintain the tenancy despite Godofredo's death.

Republic Act Number 6657, the Comprehensive Agrarian Reform Law, was invoked by the respondents against their ejectment. The Court noted their assertion that the petitioner's act of ejecting them and repossessing the property is in violation of this law, which protects the security of tenure of agrarian beneficiaries.

Ruling

On the first issue, the Court held that a tenancy relationship existed. The findings of the Provincial Adjudicator and the Board that the Mauricios were former tenants, supported by the testimony of the Municipal Agrarian Reform Officer and the certification of the Barangay Agrarian Reform Council president, are findings of fact entitled to respect. The Court ruled that Reyes's clean title cannot defeat the tenancy, and that the kasunduang buwisan executed between his sister Susana and Godofredo affirmed a tenancy that began in 1973. His lack of consent did not invalidate it, because a tenancy relationship cannot be extinguished by mere expiration of term or by the sale, alienation, or transfer of legal possession of the landholding. The Court also held that the property's agricultural nature and the requisites of tenancy are questions of fact best left to the agrarian bodies.

On the second issue, the Court held that the Board did not exceed its jurisdiction. It affirmed the annulment of the kasunduan, since the tenancy relation survived and the document could not be used to dissolve it. The Court also upheld the substitution of Leonida for Librada, ruling that the petitioners cannot collaterally attack her status in this petition.

Doctrine

A tenancy relationship, once established, is not extinguished by the expiration of the term of a leasehold contract, nor by the sale, alienation, or transfer of legal possession of the landholding. The tenant's heirs succeed to the tenancy relation by operation of law under Republic Act Number 3844. A clean certificate of title without any annotation of tenancy does not defeat a tenancy that is proved by the records and by the certifications of agrarian officials. Findings of fact of the Provincial Adjudicator and the Department of Agrarian Reform Adjudication Board on the existence of tenancy and the agricultural nature of the land are entitled to respect and finality.

Disposition

The Supreme Court denied due course to the petition and affirmed the decision and resolution of the Department of Agrarian Reform Adjudication Board, so that the kasunduan was declared null and void and the respondents' peaceful possession was upheld, subject to the return of the 50,000 pesos.

Remember This

Memorize this line: a tenancy relation is not extinguished by the expiration of the term or by the transfer of the land, and the tenant's heirs succeed to it by operation of law. Examiners use this case to test the security of tenure of tenants and heirs and the respect accorded to the factual findings of agrarian adjudicators.