RUFINA VDA. DE TANGUB vs.

COURT OF APPEALS, PRESIDING JUDGE of the [CAR] RTC, Branch 4, Iligan City,
and SPOUSES DOMINGO and EUGENIA MARTIL,
[UDK No. 9864 : December 3, 1990.] NARVASA, J.:
FACTS: 1. Rufina Tangub and her husband, Andres, now deceased, filed with the Regional Trial Court of Lanao
del Norte "an agrarian case for damages by reason of the(ir) unlawful dispossession . . .was tenants from the
landholding" owned by the Spouses Domingo and Eugenia Martil.
2. Several persons were also impleaded as defendants, including the Philippine National Bank, it being
alleged by the plaintiff spouses that said bank, holder of a mortgage on the land involved;
3. ome time later, of portions of the land to the other persons named as its co-defendants (all employees of
the National Steel Corporation), and it being prayed that mortgage and the transactions thereafter made in
relation thereto be annulled and voided;
4. The complaint was dismissed, by virtue of Executive Order No. 229 "providing the mechanisms for the
implementation of the Comprehensive Agrarian Reform Program approved on July 24, 1987" Executive No.
129-A approved on July 26, 1987, as well as the Rules of the Adjudication Board of the Department of
Agrarian Reform, jurisdiction of the Regional Trial Court over agrarian cases had been transferred to the
Department of Agrarian Reform;
5.The Tangub Spouses filed a petition for Certiorari with this Court, docketed as UDK-8867, assigned to the
Second Division;
6. this Court referred the same to the Court of Appeals, that tribunal having concurrent jurisdiction to act
thereon;
7. The CA dismissed the complaint finding that the jurisdictional question had been correctly resolved by the
Trial Court;
8. The petitioner Rufina Vda. de Tangub, now widowed, is once again before this Court, contending that the
Trial Court's "order of dismissal re patently illegal and unconstitutional" because they deprive "a poor tenant
access to courts and directly violate R.A. 6657, PD 946, and Batas Bilang 129.";
ISSUE: WON The jurisdiction of the Regional Trial Court, acting as a special agrarian court, in the light of
Executive Orders Numbered 129-A and 229 and Republic Act No. 665.
HELD: The petition is without merit.
Evidently quite as extensive as that theretofore vested in the Regional Trial Court by Presidential
Decree No. 946, which extended to the rights and obligations of persons in the cultivation and use of
agricultural land, and other matters affecting tenant-farmers, agricultural lessees, settlers, owner-cultivators,
farms' cooperatives or organizations under laws, Presidential Decrees, Orders, instructions, Rules and
Regulations in relation to the agrarian reform program. 6 Clearly, the latter must be deemed to have been
eliminated by its being subsumed in the broad jurisdiction conferred on the Department of Agrarian Reform.
The intention evidently was to transfer original jurisdiction to the Department of Agrarian Reform, a
proposition stressed by the rules formulated and promulgated by the Department for the implementation of
the executive orders just quoted. 7 The rules included the creation of the Agrarian Reform Adjudication Board
designed to exercise the adjudicatory functions of the Department, and the allocation to it;
The Regional Trial Courts have not, however, been completely divested of jurisdiction over agrarian
reform matters. Section 56 of RA 6657, on the other hand, confers "special jurisdiction" on "Special Agrarian
Courts," which are Regional Trial Courts designated by the Supreme Court at least one (1) branch within
each province to act as such.
The Regional Trial Court of Iligan City was therefore correct in dismissing Agrarian Case No. 1094. It being a
case concerning the rights of the plaintiffs as tenants on agricultural land, not involving the "special
jurisdiction" of said Trial Court acting as a Special Agrarian Court, it clearly came within the exclusive original
jurisdiction of the Department of Agrarian Reform, or more particularly, the Agrarian Reform Adjudication
Board, established precisely to wield the adjudicatory powers of the Department
WHEREFORE, for lack of merit, the petition is DISMISSED, and the Decision of the Court of Appeals in
CA-G.R. SP. No. 16725 dated October 23, 1989, AFFIRMED.
NINA M. QUISMUNDO vs HON. COURT OF APPEALS, et al. (G.R. No. 95664
REGALADO, J.)

September

13,

1991

FACTS: 1. Private respondents, as tenants of petitioner, filed a complaint with the trial court praying that their
relationship with petitioner be changed from share tenancy to a leasehold system, pursuant to Section 4 of
Republic Act No. 3844, as amended, their request therefor having been denied by petitioner;
2. Petitioner filed a motion to dismiss on the ground of lack of cause of action since the law that should
allegedly govern the relationship of the parties is Act No. 4115, as amended by Commonwealth Act No. 271,

and not Republic Act No. 3844, as amended. The trial court denied the motion for lack of merit, the
subsequent MR invoking as an additional ground the lack of jurisdiction of the court over the case under the
authority and by reason of the Comprehensive Agrarian Reform Program, specifically Executive Order No. 229
and Republic Act No. 6657. was also been denied by the court a quo;
3. An appeal was made to the CA but the latter affirmed the decision of the trial court;
ISSUE: WON the trial court has jurisdiction over the case.
HELD: We find said contention tenable.
Executive Order No. 229, which provides for the mechanism for the implementation of the
Comprehensive Agrarian Reform Program instituted by Proclamation No. 131, dated July 22, 1987, vests in
the Department of Agrarian Reform quasi-judicial powers to determine and adjudicate agrarian reform
matters.
Thus, in the case at bar, the Regional Trial Court of Angeles City, at the time private respondents filed their
complaint, was already bereft of authority to act on the same. The allegation of private respondents that their
complaint was filed on November 3, 1987, and not on February 13, 1988 as found by the Court of Appeals, is
immaterial since as of either date Executive Order No. 229 was already in effect.
The foregoing holding is further sustained by the passage of Republic Act No. 6657, the
Comprehensive Agrarian Reform Law, which took effect on June 15, 1988. The said law contains provisions
which evince and support the intention of the legislature to vest in the Department of Agrarian Reform
exclusive jurisdiction over all agrarian reform matters.
WHEREFORE, the petition at bar is GRANTED. The decision of the Court of Appeals is REVERSED and another
judgment is hereby rendered declaring NULL and VOID the orders of the lower court. The respondent judge,
or whosoever now presides over the court a quo or to which the case is assigned, is ordered to cease and
desist from further proceeding with AGRA Case No. 5176 which is hereby dismissed for lack of jurisdiction,
without prejudice, however, to the refiling of the same with the Department of Agrarian Reform.
LOPE MACHETE, et al vs COURT OF APPEALS and CELESTINO VILLALON (G.R. No. 109093
1995) BELLOSILLO, J.:

November

20,

FACTS: 1. Private respondent Celestino Villalon filed a complaint for collection of back rentals and damages
before the Regional Trial Court of Tagbilaran City against petitioners;
2. The complaint alleged that the parties entered into a leasehold agreement with respect to private
respondent's landholdings under which petitioners were to pay private respondent a certain amount or
percentage of their harvests;
3.However, despite repeated demands and with no valid reason, petitioners failed to pay their respective
rentals;
4.Petitioners moved to dismiss the complaint on the ground of lack of jurisdiction of the trial court over the
subject matter. They contended that the case arose out of or was connected with agrarian relations, hence,
the subject matter of the complaint fell squarely within the jurisdiction of the Department of Agrarian Reform
(DAR) in the exercise of its quasi-judicial powers;
ISSUE: Are Regional Trial Courts' vested with jurisdiction over cases for collection of back rentals from
leasehold tenants?
HELD: The petition is impressed with merit.
R.A. 6657 was passed containing provisions which evince and support the intention of the legislature to vest
in the DAR exclusive jurisdiction over all agrarian reform matters. Section 1, pars. (a) and (b), Rule II of the
Revised Rules of the DARAB explicitly provides
Sec. 1. Primary, Original and Appellate Jurisdiction.
xxxxxSpecifically, such jurisdiction shall extend over but not be limited to the following: (a) Cases involving
the rights and obligations of persons engaged in the cultivation and use of agricultural land covered by the
Comprehensive Agrarian Reform Program (CARP) and other agrarian laws, (b) Cases involving the valuation of
land, and determination and payment of just compensation, fixing and collection of lease rentals,
disturbance compensation, amortization payments, and similar disputes concerning the functions of the Land
Bankxxxxxxxxx (emphasis supplied)

Consequently, there exists an agrarian dispute in the case at bench which is exclusively cognizable by the
DARAB. The failure of petitioners to pay back rentals pursuant to the leasehold contract with private
respondent is an issue which is clearly beyond the legal competence of the trial court to resolve. The doctrine
of primary jurisdiction does not warrant a court to arrogate unto itself the authority to resolve a controversy
the jurisdiction over which is initially lodged with an administrative body of special competence.
Thus, respondent appellate court erred in directing the trial court to assume jurisdiction over this case.
WHEREFORE, the decision of respondent Court of Appeals as well as its resolution denying reconsideration is
REVERSED and SET ASIDE. Consequently, let the records of this case be immediately transmitted to the
appropriate Department of Agrarian Reform Adjudication Board (DARAB) for proper adjudication.
DARAB and Provincial Agrarian Reform Adjudicator FE ARCHE-MANALANG,DAR vs CA et al (G.R. Nos. 11322021. January 21, 1997) DAVIDE, JR., J.:
FACTS: These cases were consolidated in view of the fact that they involve the same petitioners and the same
issue concerning the right of BSB Construction and Agricultural Development Corp. (hereafter BSB
Construction) to develop a parcel of land into a housing subdivision, against the claim of private respondents
that they are tenant-farmers entitled to the benefits of the Comprehensive Agrarian Reform Law of 1988
(Rep. Act No. 6657).
1. The consolidated case is about the tenanted land and the BSB construction alleging that the lands in
question is residential land.
2. That, however, the petitioner filed for the cease and desist ording in the DAR for restraining the
construction, etch of the said land and to maintain the status qou betwen the parties;
3. DARAB issued a restraining order;
4.BSB Construction and Carol Baucan, who is one of the registered owners of the land in question, then filed
the petition for certiorari [under Rule 65] in this case (CA-G.R. SP No. 31179), contending that the land is not
covered by the Comprehensive Agrarian Reform Law and, therefore, the complaint filed in the DARAB is not
within the latter's jurisdiction;
CONTENTIONS: As to the first, the petitioners argue that: (1) in a special civil action for certiorari, when a
supervisory act is too specific (i.e., the 10-day period) that noncompliance therewith is proper for contempt
proceedings, the said directive is relieved of the character of an incident of supervision and becomes a
separate remedy in itself; (2) the restraining order issued by the Court of Appeals against the private
respondents was not necessary as the SQO subsisted pending finality of the ordered nullification of the BEA
Case; (3) the directive was premature and constituted undue interference with quasi-judicial proceedings
governed by a distinct set of rules, especially in light of the doctrine of primary jurisdiction; (4) any delay in
the resolution of the motion for preliminary injunction was attributable to the filing by the private respondents
of CA-G.R. SP No. 30474; and (5) since no writ was issued in the ABOGNE Case, no occasion arose for the
Court of Appeals to exercise its supervisory power.
RULINGS:
The petitioners first grievance is unfounded. Plainly, the Court of Appeals has certiorari
jurisdiction over the PARAD TRO.[7] Such jurisdiction having been invoked with the parties given sufficient
opportunity to argue for or against its propriety, the Court of Appeals could, as it did, direct the PARAD to
resolve the application for a writ of preliminary injunction within a specified period.Indisputably, the 10-day
period fixed by the Court of Appeals, counted from PARAD Manalangs receipt of a copy of the decision, can
by no means be considered arbitrary or hasty.
We likewise wish to state that there was another, more persuasive reason why CA-G.R. SP No. 30474
should be dismissed, viz., the prematurity of the petition, which amounted to a lack of cause of action. It is
precisely for this reason that the petitioners herein, as the respondents in CA-G.R. SP No. 30474, asserted in
their answer that exhaustion of administrative remedies was not had below, hence the petition lacks a cause
of action for being evidently premature.
In insisting that the DARAB had jurisdiction over the BEA Case (DARAB Case No. 0100-93 [Reg. Case
No. IV-RI-0075]), the petitioners posit that the DAR/DARAB was vested by 50 of R.A. No. 6657 with primary
jurisdiction to determine and adjudicate agrarian reform matters, and exclusive original jurisdiction over all
matters involving the implementation of agrarian reform, subject to the exceptions therein provided. Further,
the DAR/DARAB never abdicated, but merely delegated that authority to the RARADs and the PARADs under
the DARAB Revised Rules; thus, the fact that a similar case was already pending with any of the PARADs (as it
relates to provincial coverage) or RARADs (as to administrative regions of the DAR) did not, by itself,
automatically divest the DARAB of its jurisdictional competence. The petitioners finally argue that since the
function/authority/jurisdiction of the PARADs/RARADs, is only DELEGATED ... DAR/DARAB, cannot ... be said to
have totally unloaded the power/responsibility conferred by statute, to the delegate. As to the DARAB SQO,
the petitioners claim that it was issued under the DARABs original jurisdiction or in aid of its appellate
jurisdiction.
It indisputably follows that all actions pursued under the exclusive original jurisdiction of the DAR, in
accordance with 50 of R.A. No. 6657, must be commenced in the PARAD of the province where the property

is located and that the DARAB only has appellate jurisdiction to review the PARADs orders, decisions and
other dispositions.
Needless to state, the DARAB was without authority to issue the SQO, much less the warrant of arrest. Its
action was a clear violation of its DARAB Revised Rules. Any suggestion that it has unfettered discretion to
suspend its own rules is unacceptable.
WHEREFORE, the instant petition is hereby DENIED.
DOMINGO CELENDRO vs vs. COURT OF APPEALS and LEONILA VDA. DE GUEVARRA [G.R. No. 131099. July 20,
1999] PANGANIBAN, J.:
FACTS: The Petition for Review on Certiorari before us assails the decision of the CA which nullified the
decision of the DARAB. DARAB set aside the final and executory Decision of the RTC of Wao, Bumbaran Lanao
del Sur in a civil case affirming the decision of th MCTC in the same province.
1. After the death of [private respondents] husband in 1975, [private respondent] started to demand
[petitioners] eviction, but due to the latters request for extension, [petitioner] was allowed to stay in said
property and till the same. Until finally, on March 15, 1992 [private respondent] wrote a formal demand to
vacate the property and restore possession to the [private respondent]. When said demand remained
unheeded, a case for unlawful detainer was commenced by petitioner before the Municipal Circuit Trial Court
of Wao, Lanao del Sur against [petitioner].
2. Upon learning of the issuance of a writ of execution, private respondent filed a Petition to Quiet Title
before the Provincial Adjudication Board (PACB), which office rendered a decision dated October 10, 1990 in
favor of private respondent;
3. In conclusion, the CA ruled that a quasi-judicial body such as the PAAB or the DARAB could not reverse the
final decision of a judicial body such as the MCTC or the RTC.
ISSUE: The sole legal issue is whether or not the civil courts (Municipal Court and Regional Trial Court) or the
Court of Agrarian Relations or the DAR Adjudication Board ha[ve] jurisdiction over the subject matter.
HELD: The Petition is devoid of merit.
We agree with the Court of Appeals that an administrative body such as the PAAB or the DARAB
cannot reverse a courts ruling that has long become final.
First, under Rule 39, Section 47 (c) of the Rules of Court,he courts Decision has become conclusive
on the parties. They are bound by the matters adjudged and those that were actually and necessarily
included therein. Under the doctrine of conclusiveness of judgment, which is also known as preclusion of
issues or collateral estoppel, issues actually and directly resolved in a former suit cannot again be raised in
any future case between the same parties involving a different cause of action.In other words, petitioner is
barred from challenging the pronouncement of the trial court that his alleged lot is within the property of
respondents.
Second, a final judgment cannot be modified by any court, let alone by a quasi-judicial
administrative body. It is immutable and unalterable, and hence may no longer be modified in any respect
xxx.Petitioners normal recourse should have been to appeal the RTC Decision to the CA and then, if
necessary, to this Court for review. Because the trial court Decision was already final, it could not, as a rule,
be altered or questioned.More significantly, the Court has held that a final judgment can no longer be
reviewed, or in any way modified directly or indirectly, by a higher court, not even by the Supreme Court,
much less by any other official, branch or department of Government.
Finally, petitioner has actively participated in the proceedings in the MCTC and even appealed to the
RTC. He failed, however, to question either courts jurisdiction over the suit. After relying on the jurisdiction
of the regular courts, he cannot be permitted to turn around and question it. (ESTOPPEL)
WHEREFORE, the petition is hereby DENIED and the assailed Decision AFFIRMED.

G.R. No. 103953. March 25, 1999

SAMAHANG MAGBUBUKID NG KAPDULA, INC. vs. THE HONORABLE COURT OF APPEALS, et al.
PURISIMA, J.:
Facts: Macario Aro was the former owner of 2 parcels of agricultural land in Barangay Malinta, Dasmarinas,
Cavite where the members of petitioner Samahang Magbubukid Ng Kapdula, Inc. were the tenants.
The tenants were evicted when Mr. Aro sold the said land to Ricardo Silverio for the establishment of
a car assembly plant but said plant never materialized.
The lands were later leased to the spouses, Ruben Rodriguez and Gloria Bugagao, for a term of 7
years and were then developed into a sugarcane plantation, with the herein private respondents as

the regular farmworkers.

PNB acquired the same parcels of land at a Sheriffs auction sale in 1984.
In 1986, the members of petitioner sought the assistance of the Ministry of Agrarian Reform MAR,
through then Minister Heherson Alvarez, for their reinstatement as farmworkers thereon, but nothing
came out of such efforts.
Later, the ownership was transferred to the Asset Privatization Trust (APT) which conveyed the same
to the Republic of the Philippines, represented by the DAR. In furtherance of its objective of instituting
agrarian reform in the country, the DAR issued CLOA Nos. 1116 and 1117 for the said parcels of land
in favor of the petitioner.
On Petition for Certiorari, which was granted, private respondents assailed the issuance of said
CLOAs. The CA directed DAR to conduct a hearing and/or investigation to determine the rightful
beneficiaries of the subject parcels of land and to cause the cancellation of the CLOA-1116 and 1117
should petitioners be found not entitled to the subject parcels of land.
Issue: Whether there was a need for the private respondents to exhaust administrative remedies before
filing their petition for certiorari with the Court of Appeals.
Held:

From the DARAB Revised Rules of Procedure, it can be gleaned that decisions of the DAR Secretary
cannot be questioned before DARAB. Pertinent rules, provide:
SECTION 1. Primary, Original and Appellate Jurisdiction. The Agrarian Reform Adjudication
Board shall have primary jurisdiction, both original and appellate, to determine and
adjudicate all agrarian disputes, cases, controversies, and matters or incidents involving the
implementation of the Comprehensive Agrarian Reform Program under Republic Act No. 6657,
Executive Order Nos. 229, 228 and 129-A, Republic Act No. 3844 as amended by Republic Act
No. 6389, Presidential Decree No. 27 and other agrarian laws and their implementing rules
and regulations.
Specifically, such jurisdiction shall extend over but not be limited to the following:
xxx
(c) Cases involving the annulment or cancellation of orders or decisions of DAR officials other
than the Secretary, lease contracts or deeds of sale or their amendments under the
administration and disposition of the DAR and LBP; (Rule II, DARAB Revised Rules of
Procedure)
It is decisively clear that DARAB may only entertain appeals from decisions or orders of DAR officials
other than the Secretary. It is also irrefutable that the issuance of subject CLOAs constituted a
decision of the Secretary, who issued and signed the same.
Consequently, the propriety of the recourse by private respondents to the respondent court on a
petition for certiorari, to assail the issuance by the DAR of the CLOAs in question, is beyond
cavil. Under Section 54 of RA 6657, decisions and awards of the DAR may be brought to the Court of
Appeals by certiorari.
Time and again, this court has ruled that in cases of denial of due process, exhaustion of available
administrative remedies is unnecessary. The aggrieved party may seek judicial relief outright.

G.R. No. 129246. January 25, 2000

GREENFIELD REALTY CORPORATION and DATA PROCESSING SERVICES vs. LORETO CARDAMA,
ONOFRE CARDAMA, RAFAEL MARANAN, MARIANO CARDAMA, CECILIO CARDAMA, ROMELITO
CARDAMA, EUSEBIO PUNONG-BAYAN, GUILLERMO BANAAG, MAXIMA CARDAMA- PUNONGBAYAN
BUENA, J.:
Facts: The subject matter of this case is a parcel of land with an area of 10,744 hectares denominated as Lot
No. 2653, covered by TCT No. T-155260, registered in the name of Data Processing Services, which is
a part of a larger piece of land covering lots 3202, 2658, 2653 and 2517 with a total area of 37
hectares, more or less.
In March of 1988, private respondents filed a Complaint with the RTC of Bian, Laguna, (CAR Case No.
B-26) praying that judgment be rendered "to respect the rights of the herein plaintiffs as legitimate
leasehold tenants of their respective landholdings." Said case was dismissed on 30 August 1990
based on a compromise agreement entered into by the parties.
There was violation of the compromise agreement for which reason the private respondents instituted
DARAB Case No. IV-027293, filed with the Provincial Adjudicator of Sta. Cruz, Laguna, by the herein
private respondents
as plaintiffs, against Independent Realty Corporation, Greenfield Realty
Corporation, Data Processing Services Corporation, Pinagkaisang Uring Anak-Pawis ng Loma Sa
Agrikultura (PANALAG), and intervenors Esperidion Montanez, et al., who claimed to have already
been issued their respective Certificates of Land Transfer pursuant to Presidential Decree No. 27
which took effect on October 21, 1972, thus subject landholdings can no longer be covered by the

CARP law.
In their Amended Complaint, private respondents claimed to have succeeded their father
Hermogenes CArdama (now deceased) in the latters tenancy rights, and should be declared now as
leasehold tenants and actual tillers of the subject irrigated riceland; that the leasehold tenancy began
in the year 1978 through a verbal agreement entered into by and between defendant Independent
Realty Corporation and Hermogenes Cardama that the former had designated the latter to take over
the maintenance of said landholding which was then undeveloped and uncultivated and with the aid
of the immediate members of their respective families cleared the area from talahib, grasses and
boulders and constructed thereon all the irrigation canals until the same became productive as
irrigated riceland that said plaintiffs had been up-to-date in the payment of their lease rentals as
evidenced by the receipts issued by defendant IRC and issued by defendant Greenfield Development
Corporation.
Greenfield and Data denied the material allegations in the complaint and alleged that plaintiffs
complaint has no cause of action against said defendants; and that the present case is already barred
by laches or by final order in CAR Case No. B-26.
On June 6, 1994, a Decision was rendered by the Provincial Adjudicator which ruled that the herein
private respondents are bona fide tenants of Lot No. 2653, situated in Loma, Bian, Laguna covered
by TCT No. T-155260 and legitimate beneficiaries of the Comprehensive Agrarian Reform Law.
On appeal, the DARAB, declared that the late Hermogenes Cardama was not the bona fide tenant of
Lot 2653
Loreto Cardama, et al. filed a petition for certiorari with the Court of Appeals which reinstated the
decision of the Provincial Adjudicator.
Issues:1. The Court of Appeals erred in reversing the findings of fact of the DARAB which were based on, at
the very least, substantial evidence, and thus should have been final and conclusive upon the CA.
2. WON private respondents were guilty of forum-shopping.
3. WON res judicata applies.
Held: The petition is without merit.
1. Section 54 of Republic Act No. 6657:
JUDICIAL REVIEW
"Section 54. Certiorari. - Any decision, order, award or ruling of the DAR on any agrarian
dispute or any matter pertaining to the application, implementation, enforcement, or
interpretation of this Act and other pertinent laws on agrarian reform may be brought to the
Court of Appeals by certiorari except as otherwise provided in this Act within fifteen (15) days
from receipt of a copy thereof.
"The findings of fact of the DAR shall be final and conclusive if based on substantial
evidence."
The Court of Appeals did not err in reversing the findings of fact of DARAB, the same not being based
on substantial evidence.
Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to
support a conclusion.
The records of the case are replete with relevant evidence which are adequate to support the
conclusion that Hermogenes Cardama is the bona fide tenant of the subject property. Among such
relevant evidence are: 1.) The Joint Report Regarding The Qualification as CARP Beneficiary of Some
Members of PANALAG which states among others that "Hermogenes Cardama cultivated the subject
land during the ownership of Greenfield Development Corp./Independent Realty Corporation; and 2.)
the letter of Greenfield Development Corporation dated January 19, 1989, stating that Hermogenes
Cardama was its tenant.
2. The private respondents sufficiently explained and we quote: xxx there is no forum-shopping
between the Petition before the Honorable Court of Appeals and the case for injunction that was
pending before the Regional Trial Court of Bian, Laguna. The Petition before the Court of Appeals is
based on tenancy rights and rights under the CARL. The issue therein was whether or not petitioners
were entitled to the benefits and protection of the CARL. On other hand, the case before the RTC of
Bian was one for injunction to stop anyone from using force and intimidation to eject the lawful
possessors of Lot 2653 who are the respondents herein, petitioners before the Court of Appeals
without the benefit of a final and executory decision. "
Thus, the Court of Appeals did not err when it ruled that the issues before it were different from the
issues involved in the case then pending before the RTC of Bian.
3.
It is true that judgment upon a compromise has the effect of res judicata. But any cause of
action that arises from the application or violation of the compromise agreement cannot be said to
have been settled in said first case. Thus, petitioners claim that respondents action is barred by res

judicata is untenable.
1.
[G.R. No. 107741. October 18, 1996]
FRANCISCO BERNARTE, ET AL., vs. THE COURT OF APPEALS, ET AL.
ROMERO, J.:
Facts: Agrarian Case No. 2000 was filed before the RTC of San Fernando Pampanga by Estrella Arastia, for
violation of Section 73 (b) of Republic Act No. 6657. The complaint alleged that herein petitioners
illegally intruded into the land of the plaintiffs, burned the existing sugarcane plants and started to
cultivate small portions thereof. As a result, the land was abandoned by the civil lessee, and taken
over by plaintiff-owners. Further, there had been definite findings and rulings by the DAR that no
tenancy relationship existed between the parties. The complaint prayed for the issuance of a TRO to
enjoin petitioners from entering into the land and intruding in the possession thereof and, after
hearing, the issuance of a writ of preliminary injunction which should be made permanent after a fullblown trial.
Petitioners averred that they had been in continuous and peaceful possession of their respective
tillages since 1950. They moved for the dismissal of the complaint on the ground that the trial court
had no jurisdiction as it was the DAR, through the DARAB that had jurisdiction over the case
The lower court denied the motion to dismiss and issued a writ of preliminary injunction ordering
petitioners to desist and refrain from occupying their respective portions they are allegedly cultivating
pending the termination of the litigation, and/or unless a contrary order is issued.
Petition for certiorari, docketed as G.R. No. 100663 and entitled Jesus Bernal, et al. v. Estrella
Arastia, et al., assailing the jurisdiction of the lower court over Agrarian Case No. 2000 was
dismissed by the Supreme Court for failure to comply with Circular No. 1-88.
Meanwhile, petitioners filed before the DARAB a complaint against Estrella Arastia. Docketed as
DARAB Case No. 161-P89, the complaint alleged that on September 25, 1989, through the use and
employ of armed men, Estrella Arastia forcibly evicted and drove them out of their landholdings,
harvested and appropriated their standing rice crops, destroyed their vegetable crops, took their
deep well and set fire on their houses. They prayed for the issuance of a writ of preliminary injunction
or restraining order to enjoin defendant therein from preventing their re-entry and re-occupation of
the landholdings pending the resolution of the case.
The case was referred to the BARC who found that petitioners had been in possession and cultivation
of their respective farmholdings. Based on this findings, the DARAB issued an order declaring the
300-hectare land as within the coverage of the CARL of 1988; maintaining petitioners possession
and cultivation of their respective landholdings from where they were forcibly ejected and Estrella
Arastia from entering, intruding, and disturbing the farming activities of the said petitioners in their
respective farmholdings; directing the MARO of Lubao, Pampanga and the DAR employees
concerned to process and take appropriate action on the petition for coverage under Republic Act
6657 of their respective farmholdings in accordance with the rules and regulations of the DAR, and
dismissing for lack of merit the claims for damages.
On the strength of the said writ of preliminary injunction in DARAB Case No. 161-89, petitioners
resumed occupation and cultivation of the subject land. Such actions resulted in the dispatch of
several policemen to the area. They reminded petitioners of the writ of preliminary injunction issued
earlier in Agrarian Case No. 2000 and ordered them to leave the land in dispute.
Insisting on their right to work on the land in accordance with the writ issued in DARAB Case No.
161-89, petitioners entered the land. Petitioners were arrested for having entered the landholding
and for resisting and intimidating said police officers. Petitioners were detained at the municipal jail
of Lubao, Pampanga and were charged with direct assault upon agents of a person in authority.
Issues: 1. WON petitioners are entitled for a writ of habeas corpus.
2. WON the RTC has jurisdiction over Agrarian Case No. 2000.
Held:

NO. Once the person detained is duly charged in court, he may no longer question his detention by a
petition for the issuance of a writ of habeas corpus his remedy then is the quashal of the
information and/or the warrant of arrest duly issued.
The filing of a petition or motion for bail in cases where no bail is recommended has the same legal
import and effect as the posting of bail in cases where bail is recommended. It is settled that the
giving or posting of bail by the accused is tantamount to submission of his person to the jurisdiction
of the court.
The instant petition for habeas corpus has thus been rendered moot and academic by the filing
against petitioners of charges for direct assault on October 8, 1992 before the Municipal Trial Court of

Lubao which, on being forwarded to the Regional Trial Court of Pampanga upon the filing of an
information for direct assault on October 21, 1992 became Criminal Case No. 3171, even before the
filing of the petition for habeas corpus docketed as G.R. No. 107399. Their subsequent filing of
bailbonds to secure their provisional liberty sealed the mootness of the instant petition.
2. YES. The allegations in a complaint are determinative factors of said issue.
In filing Agrarian Case No. 2000, Estrella Arastia was merely ejecting petitioners from the land on the
ground that no tenancy relationship existed between them. However, her invocation of Sec. 73 (b) of
Republic Act No. 6657 which considers as a prohibited act forcible entry or illegal detainer by
persons who are not qualified beneficiaries under this Act to avail themselves of the rights and
benefits of the Agrarian Reform Program, obviously led the court to docket the case as Agrarian Case
No. 2000 and assume jurisdiction over it as a special agrarian court.
Such actions were in consonance with Sections 56 and 57 of said law which at vest upon the Regional
Trial Court, acting as a Special Agrarian Court, with jurisdiction over two classes of agrarian-related
cases: (1) petitions for the determination of just compensation to landowners and (2) prosecution
of all criminal offenses under the same law. A criminal offender under Republic Act No. 6657 is,
pursuant to Section 74 of the law, (a)ny person who knowingly and willfully violates the provisions of
this Act. Thus, the lower court correctly assumed jurisdiction over Agrarian Case No. 2000.
It was within petitioners rights to question the issuance of the writ before this Court through G.R. No.
100663. However, in filing the petition, they failed to comply with Circular No. 1-88. The consequent
dismissal of the case for noncompliance with said circular deprived this Court with authority to look
into the validity of the writ once again. To repeat, such dismissal constituted res judicata on the issue
of validity of the writ of preliminary injunction.
G.R. No. 143275. September 10, 2002
LAND BANK OF THE PHILIPPINES vs. ARLENE DE LEON and BERNARDO DE LEON
CORONA, J.:
Facts: The petitioners-appellees Arlene de Leon and Bernardo de Leon are the registered owners of a parcel
of land which was voluntarily offered for sale to the government at P50,000.00 per hectare. The DAR
made a counter offer but it was rejected. Another offer was made by DAR increasing the amount but
petitioners-appellees failed to respond to the new offer made so DARAB took cognizance of the case.
Subsequently, the DARAB issued an Order directing respondent-appellant LBP to recompute the value
of the subject property in accordance with DAR Administrative Order No. 6, Series of 1992. LBP
arrived at a recomputed aggregate amount of P2,491,731.65, which was again rejected.
Petitioners-appellees filed a petition with Special Agrarian Court to fix the just compensation of the
subject property. The court rendered a summary judgment fixing the compensation of the subject
property as follows: a) P1,260,000.00 for the 16.69 hectares of Riceland and b) P2,957,250.00 for the
30.4160 hectares of sugarland.
LBP filed a Motion for Reconsideration which was subsequently denied by the Court.
DAR filed in the Court of Appeals a petition for review of the decision of the Special Agrarian Court
which was assigned to its Special 3rd Division. Petitioner LBP also initiated in the Court of Appeals an
ordinary appeal which was assigned to the 4th Division of the Court of Appeals.
The Special 3rd Division of the appellate court, give due course to the petition and ordered the trial
court to recompute the compensation based on the selling price of palay at 213.00 per cavan and
ordered petitioner to pay legal interest at 6% of the compensation so fixed from 1990 until full
payment is made by the government.
The 4th Division of the Court of Appeals dismissed petitioner LBPs ordinary appeal reasoning that the
mode of appeal followed was erroneous.
Issue: What is the proper mode of appeal from decisions of the RTC, sitting as Special Agrarian Courts, in the
determination of just compensation an appeal by way of a petition for review or an ordinary
appeal?
Held: Section 2 of Rule 41 of the 1997 Revised Rules of Civil Procedure provides for three modes of appeal,
to wit:
Sec. 2. Modes of Appeal.
(a) Ordinary appeal. The appeal to the Court of Appeals in cases decided by the Regional
Trial Court in the exercise of its original jurisdiction shall be taken by filing a notice of
appeal with the court which rendered the judgment or final order appealed from and
serving a copy thereof upon the adverse party. No record on appeal shall be required
except in special proceedings and other cases or multiple or separate appeals where the
law or these Rules so require. In such cases, the record on appeal shall be filed and served

in like manner.
(b) Petition for Review. The appeal to the Court of Appeals in cases decided by the Regional
Trial Court in the exercise of its appellate jurisdiction shall be by petition for review in
accordance with Rule 42.
(c) Appeal by Certiorari. In all cases where only questions of law are raised or involved, the
appeal shall be to the Supreme Court by petition for review on certiorari in accordance with
Rule 45.
A petition for review, not an ordinary appeal, is the proper procedure in effecting an appeal
from decisions of the RTCs acting as Special Agrarian Courts in cases involving the determination of
just compensation to the landowners concerned. Section 60 of RA 6657 clearly and categorically
states that the said mode of appeal should be adopted. There is no room for a contrary
interpretation. Where the law is clear and categorical, there is no room for construction, but only
application.
What is indisputable is that Section 60 expressly regards a petition for review as the proper way of
appealing decisions of agrarian courts. So far, there is no rule prescribed by this Court expressly
disallowing the said procedure.
Unlike an ordinary appeal, a petition for review dispenses with the filing of a notice of appeal or
completion of records as requisites before any pleading is submitted. A petition for review hastens the
award of fair recompense to deprived landowners for the government-acquired property, an end not
foreseeable in an ordinary appeal. This is exemplified by the case at bar in which the petition for
review before the Special Third (3rd) Division (CA-G.R. SP No. 47005) was disposed of way ahead of
the ordinary appeal filed before the Fourth (4th) Division (CA-G.R. CV No. 60365) in the Court of
Appeals.
Inasmuch as the notice of appeal filed by petitioner LBP did not stop the running of the reglementary
period to file a petition for review, the time to appeal the decision of the Special Agrarian Court has
lapsed, rendering the said decision final and executory.EN BANC
G.R. No. 92013 July 25, 1990
SALVADOR H. LAUREL, vs. RAMON GARCIA, as head of the Asset Privatization Trust, RAUL MANGLAPUS, as
Secretary of Foreign Affairs, and CATALINO MACARAIG, as Executive Secretary
G.R. No. 92047 July 25, 1990
DIONISIO S. OJEDA, petitioner, vs. EXECUTIVE SECRETARY MACARAIG, JR., ASSETS PRIVATIZATION TRUST
CHAIRMAN RAMON T. GARCIA, AMBASSADOR RAMON DEL ROSARIO, et al., as members of the PRINCIPAL AND
BIDDING COMMITTEES ON THE UTILIZATION/DISPOSITION PETITION OF PHILIPPINE GOVERNMENT PROPERTIES
IN JAPAN
GUTIERREZ, JR., J.:
Facts: The subject Roppongi property in this case is one of the four properties in Japan acquired by the
Philippine government under the Reparations Agreement entered into with Japan on 9 May 1956. The
properties and the capital goods and services procured from the Japanese government for national
development projects are part of the indemnification to the Filipino people for their losses in life and
property and their suffering during World War II.
The Roppongi property is where the Philippine Embassy was once located before it transferred to the
Nampeida property.
A proposal was presented to President Corazon C. Aquino by former Philippine Ambassador to Japan,
Carlos J. Valdez, to make the property the subject of a lease agreement with a Japanese firm where, at
the end of the lease period, all the three leased buildings shall be occupied and used by the Philippine
government. On August 11, 1986, President Aquino created a committee to study the
disposition/utilization of Philippine government properties in Tokyo and Kobe. On July 25, 1987, the
President issued Executive Order No. 296 entitling non-Filipino citizens or entities to avail of
reparations capital goods and services in the event of sale, lease or disposition.
Amidst opposition by various sectors, the Executive branch of the government has been pushing, with
great vigor, its decision to sell the reparations properties starting with the Roppongi lot. The property
has twice been set for bidding at a minimum floor price at $225 million.
Issues:
1) Can the Roppongi property and others of its kind be alienated by the Philippine
Government?
2) Does the Chief Executive, her officers and agents, have the authority and jurisdiction, to sell the
Roppongi property?
Held:

Roppongi property is of public dominion.There can be no doubt that it is of public dominion

unless it is convincingly shown that the property has become patrimonial. This, the respondents have
failed to do.

As property of public dominion, the Roppongi lot is outside the commerce of man. It cannot be
alienated. Its ownership is a special collective ownership for general use and enjoyment, an
application to the satisfaction of collective needs, and resides in the social group. The purpose is not
to serve the State as a juridical person, but the citizens; it is intended for the common and public
welfare and cannot be the object of appropriation.
The Roppongi property is correctly classified under paragraph 2 of Article 420 of the Civil Code as
property belonging to the State and intended for some public service.
The fact that the Roppongi site has not been used for a long time for actual Embassy service does not
automatically convert it to patrimonial property. Any such conversion happens only if the property is
withdrawn from public use (Cebu Oxygen and Acetylene Co. v. Bercilles, 66 SCRA 481 [1975]). A
property continues to be part of the public domain, not available for private appropriation or
ownership until there is a formal declaration on the part of the government to withdraw it from being
such.
Abandonment of the intention to use the Roppongi property for public service and to make it
patrimonial property under Article 422 of the Civil Code must be definite. Abandonment cannot be
inferred from the non-use alone specially if the non-use was attributable not to the governments own
deliberate and indubitable will but to a lack of financial support to repair and improve the property
(See Heirs of Felino Santiago v. Lazaro, 166 SCRA 368 [1988]. Abandonment must be a certain and
positive act based on correct legal premises.
A mere transfer of the Philippine Embassy to Nampeidai in 1976 is not relinquishment of the Roppongi
propertys original purpose. Even the failure by the government to repair the building in Roppongi is
not abandonment since as earlier stated, there simply was a shortage of government funds. The
recent Administrative Orders authorizing a study of the status and conditions of government
properties in Japan were merely directives for investigation but did not in any way signify a clear
intention to dispose of the properties.
Section 63 (c) of Rep. Act No. 6657 (the CARP Law) which provides as one of the sources of funds for
its implementation, the proceeds of the disposition of the properties of the Government in foreign
countries, did not withdraw the Roppongi property from being classified as one of public dominion
when it mentions Philippine properties abroad. Section 63 (c) refers to properties which are alienable
and not to those reserved for public use or service. Rep. Act No. 6657, therefore, does not
authorize the Executive Department to sell the Roppongi property. It merely enumerates
possible sources of future funding to augment (as and when needed) the Agrarian Reform Fund
created under Executive Order No. 299. Obviously any property outside of the commerce of man
cannot be tapped as a source of funds.
2) It is not for the President to convey valuable real property of the government on his or
her own sole will. Any such conveyance must be authorized and approved by a law
enacted by the Congress. It requires executive and legislative concurrence.
Resolution No. 55 of the Senate dated June 8, 1989, asking for the deferment of the sale of the
Roppongi property does not withdraw the property from public domain much less authorize its sale. It
is a mere resolution; it is not a formal declaration abandoning the public character of the Roppongi
property. In fact, the Senate Committee on Foreign Relations is conducting hearings on Senate
Resolution No. 734 which raises serious policy considerations and calls for a fact-finding investigation
of the circumstances behind the decision to sell the Philippine government properties in Japan.
G.R. No. 113605. November 27, 1998
ROMULO ROVILLOS vs. THE HONORABLE COURT OF APPEALS, FOURTH DIVISION, THE HONORABLE
RICARDO T. LINSANGAN, PRESIDING JUDGE IN BRANCH 38 OF THE REGIONAL TRIAL COURT
OF NUEVA ECIJA, SAN JOSE CITY, AND PRIVATE RESPONDENT MODESTO OBISPO
ROMERO, J.:
Facts: Sometime in 1971, petitioner's predecessor started tilling and cultivating a portion of private
respondent's land in Carrangalan, Nueva Ecija under a "share-crop" agreement. On December 30,
1979, petitioner and the private respondent entered into a contract which stipulated that the former
was to be contracted as a farm laborer or helper responsible for the cultivation of 2 hectares of the
four hectare land. For the next five years, both parties complied with the provision of their
agreement. However, starting January 1984, petitioner no longer cultivated the land in question in
his capacity as a farm laborer but as a tenant, with the corresponding right to exclude the private
respondent from the land. To protect his interest, private respondent demanded from the petitioner
to desist from further cultivation of the said land. These demands proved futile as petitioner
continued with his daily undertakings, unmindful of private respondent's protestations.
Exasperated, private respondent, on April 9, 1984, filed a complaint against the petitioner for

Recovery of Possession with Damages with Motion for Issuance of Writ of Preliminary Injunction. In
his Answer, petitioner maintained that on October 6, 1981, he was granted a Certificate of Land
Transfer No. 0-065683 by the then Ministry of Agrarian Reform pursuant to Presidential Decree No. 27,
hence, converting his status from a farm laborer to that of a legitimate tenant of the private
respondent.
The trial court rendered a decision finding that petitioner was not a tenant but a mere farm helper or
laborer of the private respondent. This was affirmed by the Court of Appeals.
Issue: WON petitioner is an agricultural lessee and entitled to security of tenure under existing agrarian
laws.
Held: YES. A tenancy relationship exists between the parties.
First, petitioner was in actual possession of the land and resided in a farmhouse thereon as a farm
tenant would normally do. Second, the land was devoted to the production of palay and other related
products. Third, there was the element of consent, for as early as 1971, private respondent had not
instituted an action against the petitioner or his predecessor. In fact, he even allowed them and a
certain Conrado Vergara to manage and till the land. Fourth, the management of the land was for the
sole purpose of producing rice or palay. Fifth, cultivation and farm work were personally done by the
petitioner and his predecessor and Sixth, petitioner shared the harvest of the land under a "sharecrop" system. In Hernandez v. IAC, we ruled that when an individual cultivates the land and did not
receive salaries but a share of the produce, the relationship is one of tenancy and not
employment. Moreover, if private respondent's land was indeed non-tenanted, he should have
obtained a certification of non-tenancy from the then Ministry of Agrarian Reform.
Under the P.D. No. 27, farmers of rice and corn lands were deemed owners of the land they till.
However, since the land in question is only four (4) hectares, then the same cannot be subject to the
Operation Land Transfer (OLT) program of P.D. No. 27. This was to mitigate the impact of the decree
on small land owners. Consequently, no transfer of ownership can take place.
Notwithstanding the non-transfer of ownership of the landholding, it bears stressing that when the
land is seven hectares and below, the same is still covered by P.D. No. 27 under its Operation Land
Leasehold (OL) program. This means that the landowners and the tenants are placed in a leasehold
relationship as of October 21, 1972, under an agricultural leasehold agreement. It is worth
mentioning that on two occasions, we have already upheld the validity of this "automatic conversion"
provision, from agricultural share tenancy to agricultural leasehold, under our land reform laws. Thus,
while owners of rice and corn lands seven (7) hectares or less are not covered by the land
transfer programs of P.D. No. 27, however, when there are tenants lands, the arrangement
immediately shifts to a leasehold relationship.
Under Section 12 of R.A. 6657, as implemented by the Department of Agrarian Reform, all tenanted
agricultural lands retained under P.D. No. 27 shall automatically be converted into agricultural
leasehold as of June 15, 1988. However, with respect to tenanted rice and corn lands, as in this case,
the leasehold relationship shall start on November 10, 1971.
G. R. No. 140164. September 6, 2002
DIONISIA L. REYES vs. RICARDO L. REYES, LAZARO L. REYES, NARCISO L. REYES and MARCELO L.
REYES
QUISUMBING, J.:
Facts: Dionisia Reyes filed a complaint for reinstatement with damages with the DARAB Region III Office
against her four younger brothers, herein respondents. She alleged that her late father, Felizardo
Reyes, was the tenant of a two-hectare agricultural lot in Parulan, Plaridel, Bulacan, owned by
Marciano Castro. After her fathers she and Marciano Castro, through the latters son and attorney-infact, Ramon R. Castro, executed a leasehold contract naming her as the agricultural lessee of the
property. However, sometime before the start of the planting of the dry season crop in 1989, herein
respondents forcibly entered the area and occupied a one-hectare portion of the property. They
claimed to be the tenants thereof. Respondents then paid rent to the Castros overseer, Armando
Duran, and continued to occupy half of the property to petitioners damage and prejudice.
Respondents denied Dionisias claim as the bona fide leasehold tenant and assert that they inherited
the lease rights to the property from their deceased father.
After attempts to amicably solve the dispute failed, the DARAB Provincial Adjudicator (PARAD) ruled
for petitioner
The DARAB-Central Office had affirmed the ruling of the Provincial Adjudicator declaring petitioner the
lawful agricultural lessee of a parcel of land in Bulacan owned by the late Marciano Castro, and thus
she is entitled to security of tenure.
On appeal, the Court of Appeals reversed the decision and held that an implied tenancy existed
between herein respondents and the landowner.

Issues:
1) Did the Court of Appeals err in disregarding the substantial evidence rule with respect to
the DARAB findings?
2) Did the appellate court commit a reversible error of law in finding that respondents had
satisfactorily met the requirements of a tenancy relationship?
Held: 1) YES. In Malate vs. Court of Appeals, we held that:
In appeals in agrarian cases, the only function required of the Court of Appeals is to determine
whether the findings of fact of the Court of Agrarian Relations are supported by substantial
evidence. And substantial evidence has been defined to be such relevant evidence as a
reasonable mind might accept as adequate to support a conclusion and its absence is not shown
by stressing that there is contrary evidence on record, direct or circumstantial, and where the
findings of fact of the agrarian court are supported by substantial evidence, such findings are
conclusive and binding on the appellate court.
Stated differently, the appellate court cannot make its own findings of fact and substitute the same
for the findings of fact of the DARAB.
A perusal of the assailed decision clearly shows that nowhere did the Court of Appeals rule that the
findings of fact of the DARAB Region III Provincial Adjudicator or the DARAB-Central Office were
unsupported by substantial evidence. Nor did the appellate court hold that said findings were made
with grave abuse of discretion on the part of the agrarian quasi-judicial agencies. An examination of
the record categorically shows that the findings of fact of the DARAB were supported by substantial
evidence. Perforce, the Malate ruling must apply to the instant case. The finding of the DARAB that
petitioner, by virtue of the contract of agricultural leasehold entered into between her and the
Castros, is the substitute tenant of the latter in lieu of her deceased father, is binding upon the
appellate court and this Court. Equally conclusive upon the court a quo and this Court is the finding
by the DARAB that respondents were mere usurpers who failed to present any proof as to the
existence of a tenancy relationship between them and the Castro family.
2) YES. The present dispute involves an agricultural leasehold. The governing law is R.A. No. 3844,
which, except for Section 35 thereof, was not specifically repealed by the passage of the R.A. No.
6657, but was intended to have suppletory effect to the latter law. Under R.A. 3844, two modes are
provided for in the establishment of an agricultural leasehold relation: (1) by operation of law in
accordance with Section 4 of the said act; or (2) by oral or written agreement, either express or
implied. By operation of law simply means the abolition of the agricultural share tenancy system and
the conversion of share tenancy relations into leasehold relations. The other method is the
agricultural leasehold contract, which may either be oral or in writing. In the instant case, it is not
disputed that an agricultural leasehold contract was entered into between petitioner and Ramon
Castro.
Regardless of the number of years that Duran had been the overseer of the Castros, there is
absolutely no showing that he was ever authorized to appoint tenants or successor-tenants for the
Castros, nor to accept rentals from the persons he would appoint. Absent substantial evidence to
show Durans authority from the Castros to give consent to the creation of a tenancy relationship, his
actions could not give rise to an implied tenancy. In fact, Duran admitted that he was aware of the
existence of the leasehold contract between petitioner and the Castros, naming the former as the
successor-tenant to the property. Since an implied tenancy between the same landowners and
respondents is incompatible with this express and written leasehold contract and given
the absolute lack of substantial evidence to support the existence of an implied tenancy,
the express tenancy contract must be maintained.
The receipts issued to respondents do not bear the name and signature of Ramon Castro. Given these
circumstances, Ramon Castro cannot be deemed estopped from denying the existence of a tenancy
relationship between him and respondents.
One final note. Respondents original stance before the DARAB that they had inherited or succeeded
to the tenancy rights of their late father is likewise erroneous. As correctly found by the DARAB:
Defendants-Appellants should not confuse the law on succession provided for in the Civil Code of
the Philippines with succession in agrarian cases. In the former, (the) statute spreads the estate
of the deceased throughout his heirs; while in agrarian laws, the security of tenure of the
deceased tenant shall pass on to only one (1) heir in the manner provided for in Section 9