Reyes v. Reyes

G.R. No. 140164, 6 September 2002


As disclosed by the record, the instant case stemmed from a complaint for reinstatement with damages filed with the DARAB Region III Office by Dionisia Reyes on April 22, 1991 against her four younger brothers, herein respondents. She alleged that her father, the late Felizardo Reyes, was the tenant of a two-hectare agricultural lot in Parulan, Plaridel, Bulacan, owned by Marciano Castro. After her fathers death on February 17, 1989, she and Marciano Castro, through the latters son and attorney-in-fact, 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.

In their answer, respondents denied Dionisias claim that she was the bona fide leasehold tenant. They claimed that they inherited the lease rights to the property from their deceased father. Respondents pointed out that petitioner was a woman who could not possibly work or till the land by herself. They likewise averred that they were the ones actually cultivating the portion occupied by them. Hence, petitioners claim to be the lawful agricultural lessee had no basis, either in fact or in law.

After attempts to amicably solve the dispute failed, the DARAB Provincial Adjudicator (PARAD) ruled for petitioner. Respondents then seasonably appealed the PARADs judgment to the DARAB-Central Office. In its decision of September 1, 1997, however, the instant appeal was DISMISSED for lack of merit and the subject decision AFFIRMED. Respondents elevated the case to the Court of Appeals and ruled in their favor hence this appeal.


The core issue in this petition is, who among the parties should be considered the lawful and rightful tenant of the Castro property?


When an agricultural tenant dies, the choice for the substitute tenant is given to the land owner. It is the latter who has the option to place a new tenant of his choice on the land. That choice is, however, not absolute as it shall be exercised from among the surviving compulsory heirs of the deceased tenant. Hence, the surviving heirs cannot preempt that choice by deciding among themselves who shall take-over the cultivation or opting to cultivate the land collectively. It is only when the landowner fails to exercise such right, or waive the same, that the survivors may agree among themselves regarding the cultivation. The law is specific on the matter as so provided in Section 9, Republic Act No. 3844.

Petitioner pleads that in agrarian cases, the power of appellate review is limited to questions of law and findings of fact of the DARAB, when supported by substantial evidence, shall be binding upon the Court of Appeals. Hence, the appellate court cannot make its own findings of fact and substitute the same in lieu of the findings of the DARAB, unless there was grave abuse of discretion on the part of the DARAB. Petitioner stresses that the finding by the appellate court of Ricardos previous possession runs counter to the finding of the DARAB that Ricardo was a mere usurper who forcibly took over the disputed one-hectare portion. The appellate court also erred in finding that Ricardo and other respondents were made to believe that overseer Duran had authority to bind the Castro family to allow them to possess and cultivate the lot. This is because the DARAB found that Durans authority was limited only to collecting rentals from tenants duly appointed by the Castros, and Duran was in bad faith in accepting two rentals from Ricardo and his co-Respondents.

Petitioner asserts that Duran cannot be deemed an implied agent of the Castros under Article 1869 of the Civil Code since there are neither acts nor omissions of either Marciano Castro or Ramon Castro from which to imply an agency. Respondents insist that an agricultural leasehold contract over a one-hectare portion of the landholding arose as a result of the actions of Ramons overseer, who must be viewed as the latters agent.

While undoubtedly Duran was an agent of Ramon, he was not a general agent of the latter with respect to the landholding. The record shows that as overseer, Durans duties and responsibilities were limited to issuing receipts, selling mangoes and bamboo trees and all other things saleable. Thus, by his own admission, Duran was a special agent under Article 1876 of the Civil Code.Durans duties and responsibilities as a special agent do not include the acceptance of rentals from persons other than the tenant so designated by the landowner. Durans authority as a special agent likewise excludes the power to appoint tenants or successor-tenants. Clearly, Duran acted beyond the limits of his authority as an agent. 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.

Respondents stance before the DARAB that they had inherited or succeeded to the tenancy rights of their late father is likewise erroneous. 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. The petition is GRANTED. The decision of the CA is REVERSED and SET ASIDE. The judgment of the DARAB in affirming the decision of the Provincial Adjudicator of DARAB Region III is hereby REINSTATED.

*Case digest by Paul C. Gandola (Refresher), Andres Bonifacio Law School, SY 2019-2020

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