ALMAZAN VS. BACOLOD, G.R. NO. 227529 (16 JUNE 2021):
AFFIRMING THE JURISDICTION OF THE COURTS IN QUIETING OF TITLE CASES OVER DARAB WHEN THERE IS NO CLEAR TENANCY RELATIONSHIP
Second Part of a Two-Part Series
In the first part of this series, we discussed the ruling of the Supreme Court when it held that the Court of Appeals erred in reversing the trial court which denied the Motion to Dismiss disregarding the argument of the defendants that the Provincial Agrarian Reform Adjudicator (“PARAD”) and the Department of Agrarian Reform Adjudication Board (“DARAB”) already ruled in their favor. The Supreme Court held that aside from the fact that there is no privity between the plaintiff and the Eranas, against whom the defendants obtained favorable ruling before the PARAD and the DARAB, no tenancy exists. Hence, the trial court validly acquired jurisdiction over the case for quieting of title.
Defendants also invoked Sections 7 and 10 of Republic Act No. 3844, or the Agricultural Land Reform Code, arguing security of tenure. Specifically, Section 10 ordains that the agricultural leasehold subsists despite the change in ownership over the landholding through sale or any other mode of transfer of legal possession. The Supreme Court held that the Court of Appeals erred when it held that the plaintiff was merely subrogated to the right of the defendants’ agricultural lessor.
“Regrettably, the CA lost sight of a crucial and fundamental fact – Section 10 of RA. No. 844 applies to a transferee or successor who is subrogated to the rights of his predecessor. In this case, the petitioner cannot be regarded as a transferee or successor of the respondents’ landlord. Again, both parties admit that they have no relationship with each other whatsoever. At the risk of sounding repetitive, respondent admitted that she did not know the petitioner, and that their former landlord was Erana, and they had been remitting the shares to Erana and later, to Alcabasa and Aquino. There was no showing that Erana, Alcabasa or Aquino was the petitioner’s predecessor.
Indeed, Section 10 cannot be applied indiscriminately to a stranger or to one who is not privy to the tenancy relationship. As warned in Sialana v. Avila,‘[ u ]nless a person has established his status as a de jure tenant, he is not entitled to security of tenure nor is he covered by the Land Reform Program of the Government under existing tenancy laws.’”
Hence, this recent case of Almazan vs. Bacolod, supra, is a good case law to defeat claims of deforciants suddenly entering properties registered under the name of different persons and claiming tenancy. Citing Sialana vs. Avila, 528 Phil. 83 (2006), only legitimate tenants, i.e., either tenancy relations between the occupants/tenants and current owner or between the occupants/tenants and the current owner’s predecessor-in-interest was established, can the occupants/tenants claim that they are entitled to security of tenure.