GR 169472; (January, 2009) (Digest)
G.R. No. 169472 January 20, 2009
FRANCISCO LANDICHO, FEDERICO LANDICHO AND BUENAVENTURA LANDICHO, Petitioners, vs. FELIX SIA, Respondent.
FACTS
The case involves three parcels of agricultural land in Tayabas, Quezon, originally owned by the Aragons. The land was tenanted by Arcadio Landicho from 1949 until his death in 1972, after which his tenancy rights were succeeded by his son, petitioner Francisco Landicho. Petitioners Buenaventura Landicho (Francisco’s son) and Federico Landicho (Francisco’s brother) helped cultivate the land. On January 31, 1976, Francisco Landicho voluntarily surrendered his tenancy rights to Eloisa Zolota (married to Alberto Aragon) through a notarized “Kasulatan sa Pagsasauli ng Gawaing Palayan” for PhP1,000.00. Despite this, the petitioners continued cultivating the land until 1987, when Francisco executed another notarized “Kasulatan ng Pagsasauli ng Gawaing Palayan” on July 2, 1987, surrendering his tenancy rights to the Aragons for PhP3,000.00. On the same day, the land was sold to respondent Felix Sia. Sia converted the land to a residential subdivision without DAR Clearance and ejected the petitioners. The petitioners sought assistance from the Barangay Agrarian Reform Committee and filed protests with the DAR Provincial and Regional Legal Offices, which were dismissed, finding that Francisco was the legitimate tenant who had voluntarily surrendered his rights, and that Federico and Buenaventura were merely farm helpers. On June 10, 1994, the petitioners filed a Complaint before the DARAB for disturbance compensation and awarding of a home lot.
ISSUE
The primary issue is whether the complaint against the respondent is dismissible for lack of cause of action on the ground of prescription.
RULING
The Court of Appeals reversed the DARAB decision, finding the complaint dismissible for lack of cause of action due to prescription. The Supreme Court’s decision, as indicated by the provided text, focuses on the legal principles surrounding tenancy rights and surrender. It notes that a tenancy relationship is established by consent between the landowner and tenant, with the tenant’s personal cultivation being a fundamental element. The voluntary surrender of tenancy rights, as executed by Francisco Landicho in the 1976 and 1987 Kasulatans, extinguishes the tenancy relationship. The Court cites relevant jurisprudence and statutes, including Republic Act No. 3844 , regarding the effects of voluntary surrender and the requirements for a valid surrender. The ruling implies that since Francisco Landicho validly surrendered his rights, the petitioners’ subsequent claims, filed years later, were barred by prescription, affirming the appellate court’s dismissal of the complaint.