GR 129246; (January, 2000) (Digest)
G.R. No. 129246 . January 25, 2000.
Greenfield Realty Corporation and Data Processing Services, petitioners, vs. Loreto Cardama, Onofre Cardama, Rafael Maranan, Mariano Cardama, Cecilio Cardama, Romelito Cardama, Eusebio Punong-Bayan, Guillermo Banaag, Maxima Cardama-Punongbayan, respondents.
FACTS
The case involves a 10.744-hectare parcel of land in Biñan, Laguna, registered under Data Processing Services. Respondents, heirs of Hermogenes Cardama, claimed to be bona fide tenants, asserting they succeeded to their father’s leasehold rights from a 1978 verbal agreement with the landowner’s administrator. They filed DARAB Case No. IV-0272’93 to be declared leasehold tenants and CARP beneficiaries, presenting receipts for lease rentals as evidence. Petitioners, the corporate landowners and administrators, countered that the action was barred by a prior compromise agreement leading to the dismissal of an earlier case, CAR Case No. B-26, filed by the respondents in the Regional Trial Court.
ISSUE
The primary issues were (1) whether the respondents were bona fide agricultural tenants and legitimate CARP beneficiaries, and (2) whether the doctrine of res judicata barred the DARAB case due to the prior compromise agreement in the RTC case.
RULING
The Supreme Court affirmed the Court of Appeals’ decision, reinstating the Provincial Adjudicator’s ruling in favor of the respondents. On the substantive issue, the Court upheld the finding that Hermogenes Cardama was a civil law lessee, a status substantiated by rental receipts, and that his heirs rightfully succeeded to his tenancy rights, qualifying them as beneficiaries under agrarian reform. On the procedural issue, the Court ruled that res judicata did not apply. The prior RTC case (CAR Case No. B-26) was dismissed based on a vague compromise agreement, the terms of which were not detailed in the dismissal order. Consequently, a cause of action for the violation of that same agreement, which prompted the filing of the DARAB case, remained viable and distinct. The DARAB case properly pertained to the determination of tenancy status and CARP coverage, which fell within the exclusive original jurisdiction of the Department of Agrarian Reform Adjudication Board. Thus, the petition was dismissed for lack of merit.