GR 160882; (March, 2012) (Digest)
G.R. No. 160882 ; March 7, 2012
FELICIDAD STA. MARIA VILLARAN, WILFREDO STA. MARIA VILLARAN, DEOGRACIAS STA. MARIA and ROLANDO STA. MARIA, Petitioners, vs. DEPARTMENT OF AGARIAN REFORM ADJUDICATION BOARD and LORENZO MARIANO, Respondents.
FACTS
Bernardo Sta. Maria was a tenant-tiller under Presidential Decree No. 27 and was issued Certificates of Land Transfer in 1973, which later became the basis for Emancipation Patents and Transfer Certificates of Title (TCTs) in his name, issued in December 1988. Bernardo died in April 1988. Respondent Lorenzo Mariano entered the landholding after Bernardo’s death, claiming he was a long-time sub-tenant. Petitioners, Bernardo’s heirs, alleged Lorenzo entered by stealth and cultivated the land for his exclusive benefit, while they left it idle due to lack of rainfall. Lorenzo filed a petition before the DARAB for the disqualification of petitioners as agrarian reform beneficiaries and for the cancellation of the emancipation patents and TCTs.
The Regional Adjudicator and, on appeal, the DARAB ruled in favor of Lorenzo, ordering the cancellation of the TCTs, reallocation of the land, and maintaining Lorenzo in peaceful possession. Petitioners elevated the case to the Court of Appeals via a Petition for Certiorari under Rule 65.
ISSUE
Whether the Court of Appeals correctly dismissed the petition for certiorari and affirmed the DARAB’s decision disqualifying petitioners as beneficiaries.
RULING
Yes. The Supreme Court affirmed the Court of Appeals’ dismissal. The Court of Appeals correctly held that a petition for certiorari under Rule 65 was an improper remedy from an adverse DARAB decision. The proper remedy is a petition for review under Rule 43, to be filed within 15 days. Petitioners failed to timely avail of this correct mode of appeal.
On the substantive issue, the Supreme Court upheld the factual findings of the DARAB, which are generally binding when supported by substantial evidence. The DARAB found that Lorenzo was indeed a bona fide sub-tenant of Bernardo from 1980 until the latter’s death in 1988, a relationship prohibited under agrarian laws. This illegal sub-tenancy disqualified Bernardo, and consequently his heirs, from retaining the land under the agrarian reform program. The law mandates that the land be awarded to the actual tiller, Lorenzo, in such instances. The Court found no grave abuse of discretion in the DARAB’s application of this rule and its consequent orders for cancellation and reallocation.