CASE DIGEST: Reyes vs. Mauricio

G.R. No. 175080: November 24, 2010

EUGENIO R. REYES, joined by TIMOTHY JOSEPH M. REYES, MA. GRACIA S. REYES, ROMAN GABRIEL M. REYES, and MA. ANGELA S. REYES, Petitioners v. LIBRADA F. MAURICIO (deceased) and LEONIDA F. MAURICIO, Respondents.

Perez, J.:

FACTS:

Eugenio is the registered owner of a 4,500 square meter parcel of land acquired thru extrajudicial settlement with his co-heirs. The controversy stemmed from a complaint filed before the DARAB of Malolos, Bulacan by respondents Librada F. Mauricio (Librada), now deceased, and her alleged daughter Leonida F. Mauricio (Leonida) for annulment of contract denominated asKasunduanand between Librada and Eugenio as parties.

Respondents alleged that Eugenio took advantage of the illiteracy of Librada as she was a tenant of the father of Eugenio thru a faked notarial instrument. The Provincial Board adjudicator ruled for Librada. Eugenio lost on appeal to the DARAB and to the CA, thus the current petition

ISSUE: Whether or not there is a tenancy relation between Eugenio and Respondents.

HELD: The petition has no merit.

REMEDIAL LAW: Appeals

In the main, Eugenio insists that no tenancy relationship existed between him and Godofredo.This is a question of fact beyond the province of this Court in a petition for review under Rule 45 of the Rules of Court in which only questions of law may be raised.Absent any of the obtaining exceptionsto this rule, the findings of facts of the Provincial Adjudicator, as affirmed by DARAB and especially by the Court of Appeals, are binding on this Court.

AGRARIAN REFORM: Tenancy relations

A tenancy relationship cannot be extinguished by mere expiration of term or period in a leasehold contract; or by the sale, alienation or the transfer of legal possession of the landholding

Section 10 of Republic Act No. 3844 (Code of Agrarian Reforms of thePhilippines) likewise provides:

SEC. 10. Agricultural Leasehold Relation Not Extinguished by Expiration of Period, etc. The agricultural leasehold relation under this Code shall not be extinguished by mere expiration of the term or period in a leasehold contract nor by the sale, alienation or transfer of the legal possession of the landholding.In case the agricultural lessorsells, alienates ortransfers the legal possession of the landholding, the purchaser or transferee thereof shall be subrogated to the rights and substituted to the obligations of the agricultural lessor.

DISMISSED.