FELIPE RELUCIO III, FELICISIMA RELUCIO MAKALINAO AND MARIA RELUCIO, PETITIONERS, VS. THE HON. CATALINO MACARAIG, JR., EXECUTIVE SECRETARY, THE HON. SAMILO N. BARLONGAY, ACTING D…

Relucio versus Macaraig

The Case

This is a petition for certiorari brought by Felipe Relucio the Third, Felicisima Relucio Makalinao, and Maria Relucio against the Executive Secretary and the Acting Deputy Secretary, arising from an agrarian dispute over a small portion of a vast rice land in Cabiao, Nueva Ecija. The petitioners are the grandchildren and heirs of the original landowner, Felipe Relucio Senior, and they ask the Supreme Court to set aside the orders of the Office of the President which affirmed the ruling of the Minister of Agrarian Reform that a tenant-farmer, Arsenio Castro, is entitled to recover possession of one-half hectare of his farmholding. The case matters because it tests the deference courts give to the factual findings of administrative tribunals, and because it settles that a tenancy relationship survives the partition and transfer of the land to the owner's heirs.

Procedural History

The dispute began when Arsenio Castro filed a verified letter-complaint before the Ministry of Agrarian Reform for recovery of possession of one-half hectare of his landholding. A hearing officer, Atty. Romeo Bello, conducted a full hearing and issued an order holding that there was no tenancy relationship between Castro and the petitioners. Castro appealed to the Regional Director, and after a reinvestigation by Atty. Rustico Escoto, the Regional Director concurred in the recommendation that Castro's status as a bona fide tenant be maintained and that his Certificate of Land Transfer be upheld. The Minister of Agrarian Reform then issued an order giving due course to Castro's complaint and directing the petitioners to reconvey possession and cultivation of the one-half hectare. The petitioners appealed to the Office of the President, which affirmed the Minister's order through Acting Executive Secretary Catalino Macaraig Junior. Their motion for reconsideration was denied by Acting Deputy Secretary Samilo Barlongay. The petitioners then filed this petition for certiorari before the Supreme Court, assailing the decision as issued with grave abuse of discretion amounting to lack of jurisdiction.

Facts

In 1945, Arsenio Castro became a tenant-farmer over a riceland of about two and one-half hectares situated at Santa Rita, Cabiao, Nueva Ecija. That parcel was a portion of a vast riceland of more or less 109.7269 hectares owned and registered in the name of Felipe Relucio Senior, the grandfather of the petitioners. In 1946, Felipe Relucio Senior died, leaving as his forced heirs his two children, Felipe Relucio Junior and Lorenzo Relucio, both of whom later died.

On May 18, 1953, the heirs executed an Agreement of Partition, consolidating and subdividing the riceland into several lots. Lot Number One, with an area of 30.5680 hectares, was adjudicated to the heirs of Felipe Relucio Junior, namely the petitioners Felicisima, Maria, and Felipe the Third. Other lots were adjudicated to Rolando Relucio and to the heirs of Lorenzo Relucio. A transfer certificate of title covering Lot Number One was issued in the names of the three petitioners.

In 1972, Presidential Decree Number 27 declared the entire province of Nueva Ecija a land reform area. On October 15, 1973, Certificate of Land Transfer Number 138512 was issued to Castro, conferring on him title to the portion he actually tilled, with an area of 2.470 hectares. Castro continued to pay rentals to his landlord through the administrator, Rolando Relucio, until 1976, when Felipe Relucio the Third dispossessed him of one-half hectare, reducing his landholding to two hectares. Castro then filed his complaint in 1982 for recovery of that one-half hectare.

Issues

• Whether or not the Court should overturn the factual findings of the Minister of Agrarian Reform, as affirmed by the Office of the President, that Arsenio Castro is a bona fide tenant of the landholding.
• Whether or not the tenancy relationship between Castro and the original owner persisted despite the partition and transfer of the land to the petitioners as heirs.
• Whether or not the Certificate of Land Transfer issued to Castro should be annulled or cancelled.
• Whether or not the petitioners were deprived of due process in the proceedings before the agrarian authorities.

Applicable Provisions

Presidential Decree Number 27, the land reform law, is the measure under which Castro was issued his Certificate of Land Transfer, and the Court treats the subdivision of the land into several lots as an act done pursuant to that law. The decision refers to it as follows:

Relative thereto, petitioners laid too much stress on the fact that in their supposed tenancy relationship, private respondent failed to prove consent and consideration. As aforestated, the questioned tenancy relationship started with the original owner and persisted despite the change of ownership. The act of subdividing the whole land into several agricultural and residential lots between and among the heirs of the original owner thereby resulting in a substantial change in the boundaries of the lot awarded to private respondent pursuant to Land Reform Law cannot be invoked by petitioners to justify their claim that there is no tenancy relation between petitioners and private respondent.

This provision bears on the case because it anchors the tenant's protection in the land reform law and prevents the landowner's heirs from using a subdivision to defeat the tenancy.

Ruling

On the first issue, the Court held that it ordinarily accords respect, if not finality, to the factual findings of administrative tribunals by reason of their special knowledge and expertise. It listed the exceptions where judicial power asserts itself: where the factual findings are not supported by evidence, where they are vitiated by fraud, imposition, or collusion, where the procedure is irregular, or where palpable errors or grave abuse of discretion are manifested. Finding none of these circumstances present, the Court declined to substitute its judgment for that of the administrative body.

On the second issue, the Court held that while the petitioners may have become absolute owners of the land allotted to them, Castro nonetheless remained in continuous possession of the lot, which was undeniably part of the original riceland. The Court ruled that the tenancy relationship was not affected by the transfer of ownership, because the new owner assumes the rights and obligations of the previous owner. As the Court put it, tenancy right attaches to the landholding regardless of whoever may subsequently become the owner. The Court also noted that under the Land Reform Code, tenants are entitled to the enjoyment and possession of their landholdings except when their dispossession has been authorized by the Court in a judgment that is final and executory.

On the third issue, the Court found no ground to annul or cancel the Certificate of Land Transfer, because it was based on an aerial survey relied on by the Bureau of Lands as the more faithful indication of the exact area of Castro's landholding.

On the fourth issue, the Court held that there was no denial of due process, since a full hearing was conducted before the hearing officer where both parties presented oral and documentary evidence, and the reinvestigation was resolved on the basis of position papers, memoranda, and the evidence previously presented. The Court stated the governing principle:

It has already been settled that what due process abhors is not lack of previous notice but absolute lack of opportunity to be heard.

The Court added that to satisfy due process, official action must be responsive to the supremacy of reason and the dictates of justice, and that there is no denial of due process where a party was afforded every opportunity to present its case.

Doctrine

A Bar candidate should retain these rules. First, factual findings of administrative tribunals are accorded respect, if not finality, by reason of their special knowledge and expertise, and will not be overturned absent a showing that they are unsupported by evidence, vitiated by fraud, imposition, or collusion, reached through irregular procedure, or tainted by palpable error or grave abuse of discretion. Second, a tenancy relationship is not extinguished by the transfer of the landholding to the owner's heirs; the new owner assumes the rights and obligations of the previous owner, and the tenancy right attaches to the land regardless of who subsequently becomes its owner. Third, under the Land Reform Code, tenants are entitled to the enjoyment and possession of their landholdings except when their dispossession has been authorized by the Court in a judgment that is final and executory. Fourth, due process is satisfied where a party is afforded every opportunity to be heard, for what due process abhors is not lack of previous notice but absolute lack of opportunity to be heard.

Disposition

The Supreme Court dismissed the petition for lack of merit, and the orders of the Office of the President were left standing, so that Castro retained his landholding and the petitioners lost.

Remember This

The single line worth memorizing is that tenancy right attaches to the landholding regardless of whoever may subsequently become the owner thereof. Examiners like to use this case on the deference given to administrative findings of fact and on the survival of a tenancy relationship through partition and transfer of the land to the owner's heirs.