G.R. No. 194417. November 23, 2016
HEIRS OF TEODORO CADELIÑA, REPRESENTED BY SOLEDAD CADIZ VDA. DE CADELIÑA, PETITIONERS, VS. FRANCISCO CADIZ, ET AL., AND THE HONORABLE COURT OF APPEALS SPECIAL FORMER THIRD DIVISION, RESPONDENTS.

FACTS

Respondents claimed to be farmer-tenants of portions of Lot No. 7050 since 1962, instituted by Nicanor Ibuna, Sr., who then claimed ownership. In 1998, they were allegedly dispossessed following the execution of a Court of Appeals decision in a prior case (CA-G.R. CV No. 42237) which ordered the transfer of the property to Teodoro Cadeliña and his heirs, the petitioners. The respondents filed complaints for reinstatement before the DARAB. The DARAB ruled in favor of the respondents, declaring Ibuna a legal possessor with the right to institute tenants and thus recognizing respondents’ security of tenure. This decision was affirmed by the DARAB Central and a subsequent petition for review to the Court of Appeals was dismissed on procedural grounds, including insufficient verification and non-attachment of required documents.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in dismissing the petition for review based on procedural grounds.

RULING

Yes, the Court of Appeals committed grave abuse of discretion. While the proper remedy from the CA’s final resolutions was an appeal via Rule 45, not a Rule 65 petition for certiorari, the Supreme Court relaxed procedural rules to serve substantial justice. Technicalities may be set aside when their strict application would defeat the ends of justice, particularly where the case involves significant agrarian rights. The Court proceeded to resolve the substantive merits to avoid further delay.
On the merits, the Supreme Court reversed the DARAB decisions. A tenancy relationship cannot exist where the person who instituted the tenants had no legal right to the land. The prior CA decision in CA-G.R. CV No. 42237 had definitively annulled Ibuna’s titles, declaring them null and void. Consequently, Ibuna was not a legal possessor but a mere usurper. One who plants on land without any claim of right does so at his own peril. Since Ibuna had no rightful possession, he could not have lawfully instituted the respondents as tenants over the property. The DARAB therefore had no jurisdiction as no tenancy relationship was established between the rightful owners (petitioners) and the respondents. The respondents’ proper recourse was to seek a homestead grant for the land they actually tilled under the Public Land Act, not a tenancy claim.