G.R. No. 257980 (Formerly UDK-16986) - RODOLFO A. DELA CRUZ AND CELERINO A. DELA CRUZ, VS. JESUSA Y. CAILLES, REPRESENTED BY ALICIA Y. YACAT.D E C I S I O N - Supreme Court E-Library

Ruling

Accordingly, it declared the severance of their leasehold relationship with Cailles and ordered Dela Cruz et al. to vacate and surrender the subject portion to Cailles. [13] Dela Cruz et al. appealed to the DARAB. The DARAB Ruling In a Decision [14] dated July 23, 2018, the DARAB reversed and set aside the PARAD ruling, declaring that there was no valid cause to terminate the leasehold relation and ordering Cailles to respect and maintain the Dela Cruzes' peaceful possession and cultivation of the subject land. It held that the subject deed was not convincing enough to sustain Cailles's claim that the Dela Cruzes had voluntarily surrendered their tenancy right over the subject land as the latter were uneducated and were merely coaxed into signing a document that they believed to be mere proof of a loan transaction. It also found no showing that they had a clear, absolute or irrevocable intention to abandon the landholding considering that they remained in active physical cultivation of the subject land, as corroborated by farmers of the adjacent landholding and the receipts issued by Yacat and other duly authorized representatives acknowledging payment of lease rentals even after the execution of the subject deed on June 29, 2006. These further showed that Cailles, through Yacat, had consented to the loan transaction between the Dela Cruzes and Carlito and to the construction of the house on the subject portion. [15] Dissatisfied, Cailles appealed to the CA. The CA Ruling In a Decision [16] dated July 7, 2020, the CA reversed and set aside the DARAB ruling and reinstated the PARAD ruling. It held that the DARAB erred in not giving evidentiary weight to the subject deed, which is a notarized document entitled to full faith and credit upon its face, absent clear, convincing, and more than preponderant evidence to controvert the same. The CA held that the deed was written in plain Filipino language that ordinary people can understand and all of the named parties signed the deed, rendering it improbable that not even one of them understood its plain import. Lastly, it added that the deed was notarized by the counsel of the Dela Cruzes, Atty. Mario M. Pangilinan. [17] The CA likewise declared that the Dela Cruzes committed serious violation of their obligation as tenants, specifically, under Section 36(2) and (7) [18] of Republic Act No. 3844, as tillage did not remain under the exclusive administration of the tenant's family. It held that while they denied abandoning the subject land, they never denied that Carlito was in possession of it and had constructed a house on it even though he was not an agricultural lessee. [19] Finally, the CA ruled that the receipts of payments issued by Yacat and other authorized representatives do not show that Carlito was validly in possession as it did not establish Cailles's consent to his possession. [20] Dela Cruz et al. moved for reconsideration, which was denied in a Resolution [21] dated March 23, 2021. Hence,