Brada and her daughter, Leoni, filed a complaint before the Department of Agrarian Reform Adjudication Board (DARAB). They alleged that they are the legal heirs of the late Godo, who was the lawful and registered tenant of Eugene. Brada claimed that Godo had been working on the land since 1936 until his death in 1994. It was Godo who introduced improvements such as fruit bearing trees, seasonal crops and a house. She presented the Kasunduang Buwisan sa Sakahan dated 26 May 1993 which reaffirmed the leasehold tenancy of Godo over the subject land.
Brada further claimed that after Godo’s death, Eugene, an heir of the landowner, deceitfully caused the preparation of another document simply denominated as the Kasunduan executed in 1994, to eject the mother and daughter from the subject property. According to Brada, Eugene had the Kasunduan notarized even when she did not appear before the notary public. She also represented that she could not have known the contents thereof because she is illiterate. So, Brada and Leoni averred that the Kasunduan is void for lack of consent. Mother and daughter sought the declaration of nullity of the Kasunduan and for an order for Eugene to maintain and place them in peaceful possession and cultivation of the subject property.
Eugene countered that no tenancy relationship existed between him and Branda and Leoni. Eugene maintained the validity of the 1994 Kasunduan which effectively terminates the leasehold tenancy when Brada allegedly agreed to vacate the subject premises in exchange of monetary considerations. Finally, Eugenio also asserted that Leonida had no legal personality to file the present suit. He claimed that the complaint was rendered moot with the death of Brada, Godo’s sole compulsory heir. Eugenecontended that Leonida is a mere ward of Godofredo and Librada, thus, not a legal heir.
Q: Whether or not the 1994 Kasunduan is valid?
A: No. The High Court deferred to the findings of the DARAB and the appellate courts. The Supreme Court upheld the applicability of the principle that in all contractual, property or other relations, when one of the parties is at a disadvantage on account of his moral dependence, ignorance, mental weakness or other handicap, the courts must be vigilant for his protection (Art. 24, New Civil Code). In the case at bar, Plaintiff-Appellee is already eighty-one (81) years old who can neither read nor write, thus, she just simply signs her name with her thumbmark.
Q: Assuming that the Kusunduan is valid, was the agricultural tenancy terminated?
A: No, 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 9 of Republic Act No. 1199 or the Agricultural Tenancy Act provides:
SECTION 9. Severance of Relationship. — The tenancy relationship is extinguished by the voluntary surrender of the land by, or the death or incapacity of, the tenant, but his heirs or the members of his immediate farm household may continue to work the land until the close of the agricultural year. The expiration of the period of the contract as fixed by the parties, and the sale or alienation of the land does not of themselves extinguish the relationship. In the latter case, the purchaser or transferee shall assume the rights and obligations of the former landholder in relation to the tenant. In case of death of the landholder, his heir or heirs shall likewise assume his rights and obligations. (Emphasis supplied)
Moreover, Section 10 of Republic Act No. 3844 (Code of Agrarian Reforms of the Philippines) 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 lessor sells, alienates or transfers 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. (Emphasis supplied)
Q: Whether Eugene can impugn the legitimacy of Leoni in order to establish that Leoni has no legal standing as a party?
A: No. Eugene cannot collaterally attack the status of Leonida in the instant petition.
It is settled law that filiation cannot be collaterally attacked. Well known civilista Dr. Arturo M. Tolentino thus explained:
The legitimacy of the child cannot be contested by way of defense or as a collateral issue in another action for a different purpose. The necessity of an independent action directly impugning the legitimacy is more clearly expressed in the Mexican code (article 335) which provides: “The contest of the legitimacy of a child by the husband or his heirs must be made by proper complaint before the competent court; any contest made in any other way is void.” This principle applies under our Family Code. Articles 170 and 171 of the code confirm this view, because they refer to “the action to impugn the legitimacy.” This action can be brought only by the husband or his heirs and within the periods fixed in the present articles.
Source: Reyes vs. Mauricio, G.R. No. 175080, November 24, 2010
Ma. Soledad Deriquito-Mawis is dean, Lyceum of the Philippines University; trustee, Philippine Association of Law Schools; and founder of Mawis Law Office