G.R. No. 170182 June 18, 2009
LEONARDO TARONA, EUGENIA TARONA, NITA TARONA, LUIS TARONA, ROSALINDA TARONA, APOLONIA TARONA, CARLOS TARONA, LOURDES TARONA and ROGELIO TARONA, Petitioners, vs. COURT OF APPEALS (NINTH DIVISION), GAY T. LEAÑO, LEMUEL T. LEAÑO, NOEL T. LEAÑO, JEDD ANTHONY LEAÑO CUISON and JASON ANTHONY LEAÑO CUISON, Respondents.

FACTS

The case involves a parcel of land in Morong, Bataan, registered in the name of Antonia T. Leaño. Upon Antonia’s death, her children (private respondents Leaños) inherited the land. They filed a complaint for recovery of possession against petitioners Leonardo, Eugenia, Nita, Luis, and Rosalinda Tarona, alleging the Taronas were not lawful tenants. Other petitioners (Apolonia, Carlos, Lourdes, and Rogelio Tarona) later intervened. The Taronas claimed to be bona fide leasehold tenants, having succeeded to the tenancy rights of their predecessor, Juanito Tarona, based on a 1956 Leasehold Agreement between Juanito Tarona and Federico Leaño (Antonia’s husband). The Provincial Adjudicator (PARAD) dismissed the complaint, upholding the Taronas’ tenancy status. The DARAB affirmed this decision. The Court of Appeals reversed the DARAB, ruling that: (1) Leonardo, Eugenia, Nita, Luis, and Rosalinda Tarona could not succeed to tenancy rights as they are only nephews/nieces of the original tenant, and succession under agrarian law is limited to direct descendants; and (2) Apolonia, Carlos, Lourdes, and Rogelio Tarona could not be considered tenants as they were not residents of the land’s location (Morong, Bataan), evidenced by certifications showing they were residents/voters of Caloocan City. The CA also noted that in a separate DAR administrative case, only 1.2854 hectares of the land was declared subject to CARP coverage.

ISSUE

The primary issue is whether a tenancy relationship exists between the parties, specifically: (1) whether the petitioner Taronas can validly succeed to the tenancy rights of Juanito Tarona; and (2) whether the intervenor Taronas can claim tenancy status despite not being residents of the land’s location.

RULING

The Supreme Court denied the petition, affirming the Court of Appeals’ decision. The Court held that the findings of the CA on the absence of a tenancy relationship were binding, as they were supported by substantial evidence and the Court found no reason to deviate from them. On the first issue, the Court agreed with the CA that under Section 9 of Republic Act No. 3844 (Agricultural Land Reform Code), the right to succeed to tenancy is limited to the tenant’s spouse and/or direct descendants. Since Leonardo, Eugenia, Nita, Luis, and Rosalinda Tarona are merely nephews and nieces of the original tenant Juanito Tarona, they are not compulsory heirs and cannot succeed to his tenancy rights. On the second issue, the Court upheld the CA’s finding that Apolonia, Carlos, Lourdes, and Rogelio Tarona were not residents of Morong, Bataan, where the land is situated. Personal cultivation, a requisite for tenancy, requires the tenant’s physical presence in the landholding. Their residence in Caloocan City negated their claim of personally cultivating the land in Bataan. The Court also addressed the CARP coverage issue, stating that the determination of land classification and coverage is an administrative function vested in the DAR Secretary, not the DARAB. Therefore, the DARAB and the PARAD had no jurisdiction to rule on the CARP coverage of the land, and the CA correctly relied on the existing order from the DAR Regional Director in the separate administrative case.