GR 141593; (July, 2006) (Digest)
G.R. Nos. 141593-94 ; July 12, 2006
MELENCIO BERBOSO AND CONCEPCION BERBOSO, petitioners, vs. HON. COURT OF APPEALS, BELEN CARLOS, CORAZON CARLOS, AND JKM INTERNATIONAL, respondents.
FACTS
The case involves a parcel of agricultural land owned by the Carlos family. On 22 January 1975, the Department of Agrarian Reform (DAR) Secretary issued an Order converting the land to residential, commercial, industrial, or other urban purposes, subject to payment of disturbance compensation to the tenant-farmers. The Carloses paid the compensation to their tenants. However, petitioners Melencio and Concepcion Berboso, successors-in-interest of an original tenant, refused to vacate their landholding. The Carloses subsequently sold portions of the converted land to respondent JKM International, Inc.
The Carloses filed a petition with the DAR Adjudication Board (DARAB) for confirmation of the conversion and determination of disturbance compensation. A joint motion was filed by the Carloses and Emiliano Berboso (the petitioners’ brother and the named respondent in the DARAB case) to determine the compensation amount. The DARAB ordered payment to Emiliano. Petitioners later asserted they were also tenants on distinct landholdings and should have been included in the proceedings. They filed a separate action for maintenance of peaceful possession.
ISSUE
The core issue is whether the DARAB decision, which arose from proceedings where only Emiliano Berboso was named as a respondent-tenant, is binding upon petitioners Melencio and Concepcion Berboso who claim to be tenants on separate and distinct portions of the land.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic rests on the principle of conclusiveness of judgment and the nature of the DARAB’s conversion order. The 1975 DAR conversion order was issued for the entire landholding, not for specific tenant plots. The subsequent DARAB case was for the confirmation of this conversion and the fixing of disturbance compensation for the tenants affected by the entire conversion order.
Petitioners, by claiming to be tenants on separate portions of the same converted landholding, are considered successors-in-interest to the original tenants and are bound by the DARAB’s final and executory decision in the case where their predecessor was a party. They cannot collaterally attack that judgment in a separate action for peaceful possession. Their remedy was to intervene in the original DARAB case or appeal the decision, which they did not do. The conversion order, having become final, legally extinguished tenancy relations on the land, and the subsequent sale to JKM was valid. The Court upheld the reinstatement of JKM’s titles.