In Lercana v. Jalandoni, the Supreme Court addressed a dispute over agricultural land ownership and tenancy rights. The Court affirmed the Court of Appeals’ decision, which upheld the Department of Agrarian Reform Adjudication Board’s (DARAB) ruling, recognizing the respondents as the rightful tenants of the entire disputed property. This case highlights the importance of substantial evidence in determining tenancy status and the limited scope of judicial review when factual findings are supported by the record. Moreover, it underscores that the identification of beneficiaries under the Comprehensive Agrarian Reform Program (CARP) is an administrative function solely within the jurisdiction of the Department of Agrarian Reform (DAR).

Land Disputes Unveiled: Who Has the Right to Till?

The case revolves around a parcel of agricultural land initially owned by Gregorio Pajuelas, the grandfather of the petitioner, Lolihala Lercana. After a series of mortgages and a subsequent foreclosure by the Philippine Veterans Bank (PVB), the land’s ownership became a point of contention. The respondents, led by Porferio Jalandoni, claimed they were legitimate tenants installed by Rodolfo Aspilla, who had previously redeemed the land. This claim was challenged by Lercana, who asserted her ownership based on an alleged purchase from PVB and argued that the respondents were not valid tenants. The central legal question was whether the respondents had established their rights as tenants, entitling them to remain on the land despite Lercana’s claim of ownership.

The dispute began when Lercana claimed ownership and demanded a share of the land’s produce from the respondents. Dissatisfied with their response, she took over the land, prompting the respondents to file a complaint for reinstatement and damages before the Department of Agrarian Reform (DAR). The Provincial Adjudication Board (PARAD) initially dismissed the complaint. However, the DARAB reversed this decision, declaring the respondents as de jure tenants and ordering Lercana to vacate the property. The Court of Appeals affirmed the DARAB’s decision, leading Lercana to seek recourse before the Supreme Court.

At the heart of the matter was the determination of tenancy. The Supreme Court emphasized that the Court of Appeals’ finding, affirming the DARAB’s decision, was supported by substantial evidence. The Court cited the testimony of Galoy Ezoy, a witness for Lercana, which confirmed that the respondents were appointed to work on the land by Aspilla. The Court noted the certifications from the Barangay Agrarian Reform Committee (BARC) and the Municipal Agrarian Reform Officer, which stated that Lercana and her relatives were not the actual occupants and tillers of the land, further undermining her claim. Moreover, the Supreme Court emphasized the importance of deferring to the factual findings of the appellate court, especially when they are consistent with the evidence on record.

Regarding Lercana’s claim to the eastern portion of the land, the Court found it lacking. The certifications and testimony presented indicated that Lercana and her relatives had taken over the land only recently. In agrarian cases, the quantum of evidence required is substantial evidence, which the respondents had successfully presented to support their claim as tenants. Lercana’s evidence, including the DARAB Sheriff’s certification, only attested to her actual cultivation at the time of the case’s pendency but did not negate the fact that the respondents were the rightful tenants.

The Supreme Court also addressed the issue of CARP beneficiaries. The Court clarified that the determination of who should be the beneficiaries under the CARP is an administrative matter within the exclusive jurisdiction of the Department of Agrarian Reform (DAR). The DARAB, in its decision, had correctly left this determination to the concerned DAR offices. The Supreme Court reinforced that such matters are beyond the jurisdiction of the DARAB and rest solely with the Secretary of the DAR. This distinction emphasizes the separation of adjudicative and administrative functions within the agrarian reform process.

Building on this principle, the Supreme Court held that the Court of Appeals did not err in affirming the DARAB’s decision, which recognized the respondents as tenants. The Court highlighted that the identification and selection of CARP beneficiaries are strictly administrative matters under the purview of the DAR. The case reinforces the importance of substantial evidence in proving tenancy rights and clarifies the jurisdictional boundaries between the DARAB and the DAR Secretary in implementing agrarian reform.

FAQs

What was the key issue in this case?	The central issue was whether the respondents were legitimate tenants of the disputed land, entitling them to reinstatement despite the petitioner’s claim of ownership. The Court examined the evidence presented by both sides to determine the actual occupants and tillers of the land.
What evidence did the respondents present to support their claim of tenancy?	The respondents presented testimony from a neighbor, certifications from the Barangay Agrarian Reform Committee (BARC), and the Municipal Agrarian Reform Officer. These pieces of evidence collectively indicated that the respondents were the actual occupants and tillers of the land.
What was the role of the Department of Agrarian Reform (DAR) in this case?	The DAR played a critical role, as the Department of Agrarian Reform Adjudication Board (DARAB) reversed the Provincial Adjudication Board’s decision, recognizing the respondents as tenants. Furthermore, the DAR is responsible for identifying beneficiaries under the Comprehensive Agrarian Reform Program (CARP).
Why did the Supreme Court uphold the Court of Appeals’ decision?	The Supreme Court upheld the Court of Appeals’ decision because it found that the appellate court’s decision, affirming the DARAB’s ruling, was supported by substantial evidence on record. This included the testimonies and certifications confirming the respondents’ tenancy.
What is the significance of “substantial evidence” in agrarian cases?	In agrarian cases, “substantial evidence” is the quantum of proof required to establish a claim, meaning such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The respondents successfully met this threshold in proving their tenancy rights.
Who has the authority to determine CARP beneficiaries, and why?	The Secretary of the Department of Agrarian Reform (DAR) has the exclusive authority to determine CARP beneficiaries. This is because the identification and selection of beneficiaries are administrative matters strictly within the DAR’s purview.
What was the basis of the petitioner’s claim to the land?	The petitioner claimed ownership of the land based on an alleged purchase from the Philippine Veterans Bank (PVB) after it was foreclosed. However, the evidence presented did not sufficiently support her claim of continuous occupation and tillage.
Can this ruling be applied to all tenancy disputes?	While this ruling provides guidance on determining tenancy rights based on evidence, each case is fact-specific. The principles established here, such as the importance of substantial evidence and the DAR’s role in CARP implementation, are generally applicable but must be assessed within the context of individual circumstances.

In conclusion, Lercana v. Jalandoni reiterates the importance of evidence-based decision-making in agrarian disputes and underscores the administrative role of the DAR in CARP implementation. This case serves as a reminder that tenancy rights are protected under the law, and claims of ownership must be substantiated with credible evidence. Additionally, it clarifies the jurisdictional boundaries between the DARAB and the DAR Secretary in matters pertaining to agrarian reform.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Lolihala Saberon Lercana v. Porferio Jalandoni, G.R. No. 132286, February 01, 2002