G.R. No. 178672 March 19, 2009
JULIO MERCADO, Petitioner, vs. EDMUNDO MERCADO, Respondent.

FACTS

Petitioner Julio Mercado was a tenant of an agricultural land owned by the grandfather of respondent Edmundo Mercado. In 1976, petitioner was issued a Certificate of Land Transfer (CLT) under Presidential Decree No. 27, and an Emancipation Patent (EP) in 1982. On August 1, 1994, respondent, relying on a Certificate of Retention (CR) issued in his name based on his grandfather’s “Huling Habilin,” filed a complaint before the Provincial Adjudication Board (PARAB) of the DARAB for rescission of contract, cancellation of the CLT and EP, payment of rental arrears, and ejectment. Respondent alleged the CLT and EP were irregularly issued as the property was covered by his CR, and that petitioner had not paid rentals since 1979. The PARAB dismissed the complaint, upholding the validity of the EP. On appeal, the DARAB reversed the PARAB, finding petitioner guilty of deliberate non-payment of lease rentals under P.D. No. 816 and R.A. No. 3844 , as amended. The DARAB ordered the rescission of the leasehold contract, ejectment of petitioner, and cancellation of the CLTs. This decision became final and executory, and a writ of execution was issued. Petitioner subsequently filed a Petition for Certiorari with the Court of Appeals, which was dismissed due to the finality of the DARAB decision. Petitioner then filed a Petition for Review on Certiorari before the Supreme Court, which was denied due to procedural flaws. Undaunted, petitioner filed a Petition for Relief from Judgment with the DARAB itself, which was denied. He challenged this denial via a Petition for Review before the Court of Appeals, which also denied it. Hence, the present petition.

ISSUE

The primary issue is whether the Court of Appeals erred in affirming the DARAB’s denial of petitioner’s Petition for Relief from Judgment and in upholding the final and executory DARAB decision which found petitioner guilty of deliberate non-payment of lease rentals, ordered rescission of the contract, and cancellation of his CLT and EP.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals Decision. The Court held that the DARAB decision in DARAB Case No. 4389 had long become final and executory, hence immutable and unalterable. A final judgment may no longer be modified except for: 1) clerical errors, 2) nunc pro tunc entries causing no prejudice, or 3) void judgments. None of these exceptions applied. Petitioner’s contention that the DARAB decision was void for lack of jurisdiction—arguing no tenancy relationship existed after the EP issuance—was without merit. Jurisdiction is determined by the allegations in the complaint. Respondent’s complaint alleged a tenancy relationship, including elements like landowner-tenant relationship, agricultural land, consent, agricultural production, personal cultivation, and harvest sharing. Furthermore, the mere issuance of an emancipation patent does not place ownership beyond attack; EPs can be cancelled for violations of agrarian laws, and the DARAB has jurisdiction over such cancellation cases. The Court also noted petitioner actively participated in the proceedings and could not question jurisdiction at a late stage. Regarding the Petition for Relief from Judgment, the Court found it unavailable as relief under the DARAB Rules is only against the decision of an adjudicator, filed with that adjudicator, when no other adequate remedy exists. Petitioner sought relief from the DARAB’s decision before the DARAB itself, which was improper. Finally, the Court found no deprivation of due process, as petitioner had the opportunity to be heard but failed to vigilantly protect his rights.