G.R. No. 172841; December 15, 2010
RENATO REYES, represented by RAMON REYES, Petitioner, vs. LEOPOLDO BARRIOS, substituted by LUCIA MANALUS-BARRIOS, Respondent.

FACTS

Petitioner Renato Reyes, a co-owner of a parcel of land in Candaba, Pampanga, filed a complaint for ejectment against respondent Leopoldo Barrios before the Provincial Agrarian Reform Adjudicator (PARAD). Petitioner alleged that the 3.6-hectare landholding was retained from Operation Land Transfer and that respondent was merely hired as an overseer of the farm and piggery, who failed to remit proceeds. Respondent countered that he was a bona fide tenant since 1972, built his house on the land, and cultivated it. The PARAD ruled in favor of petitioner, ordering respondent’s ejectment.
Respondent appealed to the Department of Agrarian Reform Adjudication Board (DARAB). During the appeal’s pendency, respondent died and was substituted by his spouse, Lucia Manalus-Barrios. The DARAB reversed the PARAD, declaring respondent a bona fide tenant who could not be ejected absent a justifiable cause under agrarian law. It ordered petitioner to reinstate the qualified heir and directed the issuance of a Certificate of Agricultural Lease. Petitioner’s motion for reconsideration was denied. The Court of Appeals affirmed the DARAB decision, prompting this petition.

ISSUE

Whether the Court of Appeals erred in affirming the DARAB’s ruling that Leopoldo Barrios was a bona fide tenant, not subject to ejectment.

RULING

The Supreme Court denied the petition and affirmed the assailed rulings. The Court held that the DARAB and the Court of Appeals correctly found respondent to be a bona fide tenant based on substantial evidence. The findings were supported by a Certification from the Agrarian Reform Team listing respondent as a farmer-beneficiary and a joint statement from neighboring residents attesting to his cultivation of the land since 1972. These documents substantiated the essential elements of tenancy: consent of the parties, personal cultivation, and sharing of harvests.
The Court emphasized that technical rules of procedure are not strictly applied in agrarian cases, and the DARAB is empowered to employ reasonable means to ascertain facts. Petitioner’s claim that respondent was a mere overseer was insufficient to overturn the factual findings, which are accorded great weight and respect. Since respondent was a legitimate tenant, his security of tenure is protected. Ejectment requires a specific legal cause under Section 36 of Republic Act No. 6657, such as abandonment or voluntary surrender, none of which petitioner proved. Consequently, the tenant’s rights are transmitted to his qualified heir upon his death. The Court found no reversible error in the appellate court’s decision affirming the DARAB’s ruling.