G.R. No. 199628 April 20, 2016
HEIRS OF EXEQUIEL HAGORILES, NAMELY, PACITA P. HAGORILES, CONSEJO H. SABIDONG, CESAR HAGORILES, REYNALDO HAGORILES, ANITA H. GERONGANI, LOURDES H. CAPISTRANO, ANA LINA H. BOLUSO, and SUZETTE H. PENAFLORIDA, all represented by ANA LINA H. BOLUSO, Petitioners, vs. ROMEO HERNAEZ, MILAGROS VILLANUEVA, CRISANTO CANJA, NENA BAYOG, VENANCIO SEMILON, GAUDENCIO VILLANUEVA, VIRGINIA DAGOHOY, VIRGILIO CANJA, FELIX CASTILLO and TEOFILO HERNAEZ, GAUDENCIO ARNAEZ, BENJAMIN COSTOY, ERMIN VILLANUEVA, MARCELINO AMAR, and COURT OF APPEALS, Respondents.

FACTS

The respondents filed a complaint to maintain status quo against the late Exequiel Hagoriles and Amparo Ramos-Taleon before the Provincial Agrarian Reform Adjudicator (PARAD). They claimed to have been tenant-tillers and actual occupants of farmlands and home lots since 1967. The home lots were situated on Lot No. 2047, originally registered under Engracia Ramos, spouse of landholder Timoteo Ramos. In 1990, Exequiel Hagoriles bought a portion of Lot No. 2047 from Amparo Ramos-Taleon, daughter of Timoteo Ramos. In 1993, Exequiel successfully caused the ejectment of respondent Marcelino Amar, prompting the other respondents to file the complaint. Exequiel and Amparo denied any tenancy relations. The PARAD partly dismissed the complaint for lack of evidence on tenancy but ruled in favor of three respondents (Milagros Villanueva, Virginia Dagohoy, and Crisanto Canja) based on emancipation patents and lease receipts, entitling them to their home lots. Both parties appealed to the Department of Agrarian Reform Adjudication Board (DARAB). The DARAB affirmed the ruling for the three respondents and further declared all respondents bona fide tenants, as emancipation patents were soon to be issued to the others and they had receipts for lease rentals. However, the DARAB refused to rule on their entitlement to home lots, considering it an agrarian law implementation case outside its jurisdiction. Exequiel (substituted by his heirs, the petitioners) appealed to the Court of Appeals (CA). The CA affirmed the DARAB’s finding that all respondents were bona fide tenants and modified the decision by ruling that the DARAB had jurisdiction and that the respondents were entitled to the continuous peaceful possession of their home lots. The petitioners filed this petition for review on certiorari.

ISSUE

Whether the respondents, as bona fide tenants, are entitled to the continuous peaceful possession of their home lots on Lot No. 2047, which was purchased by the petitioners’ predecessor-in-interest.

RULING

The Supreme Court found merit in the petition. The obligation to provide a home lot rests upon the landholder under Section 26(a) of Republic Act No. 1199 (Agricultural Tenancy Act), as amended. A home lot must be located on the land of the landholder. In this case, the home lots were situated on Lot No. 2047, which was registered under Engracia Ramos, the wife of landholder Timoteo Ramos. Under the applicable old Civil Code provisions governing the property relations of spouses Timoteo and Engracia Ramos (conjugal partnership of gains), Lot No. 2047, being registered in Engracia’s name, was her exclusive property, not part of the conjugal partnership. Therefore, Timoteo Ramos, as the agricultural lessor/landholder, could not have legally designated a portion of his wife’s exclusive property as home lots for his tenants. The respondents’ possession of home lots on Engracia’s land was merely tolerated. Consequently, the petitioners, as successors-in-interest to a portion of Lot No. 2047, are not obligated as landholders to provide home lots to the respondents on that land. The respondents’ claim to home lots should be directed against their respective landholders, and such home lots should be located on the landholdings they cultivate or other lands owned by their landholders. The Court set aside the CA decision and resolution and dismissed the respondents’ complaint for lack of merit.