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EUGENIO R. REYES v. LIBRADA F. MAURICIO

FACTS:

Eugenio Reyes was the registered owner of a parcel of land located in Bocaue, Bulacan. Respondents, Librada and Leonida Mauricio, filed a complaint before the Department of Agrarian Reform Adjudication Board (DARAB) seeking the annulment of a contract between Librada and Eugenio, alleging fraud and lack of consent. Respondents claimed to be the heirs of Godofredo Mauricio, who was a tenant of Eugenio's predecessors-in-interest and had introduced improvements on the land. Eugenio contended that there was no tenancy relationship and that the contract was valid. The Provincial Adjudicator ruled in favor of Librada, declaring the contract null and void and ordering Eugenio to respect Librada's peaceful possession of the land. Eugenio appealed to the DARAB, which affirmed the Provincial Adjudicator's decision. Eugenio then filed a petition for review with the Court of Appeals, which also affirmed the DARAB's decision. Eugenio subsequently filed a petition with the Supreme Court, challenging the Court of Appeals' ruling.

ISSUES:

  1. Whether or not a tenancy relationship existed between Godofredo Mauricio and Eugenio Reyes.

  2. Whether or not the Kasunduan dated 28 September 1994 is valid and enforceable.

  3. Whether or not Leonida has the legal standing to substitute Librada Mauricio in the case.

RULING:

  1. On the existence of a tenancy relationship

    The Court upheld the findings of the DARAB and the Court of Appeals that a tenancy relationship existed between Godofredo Mauricio and the predecessors of Eugenio Reyes. The tenancy relationship cannot be extinguished by the mere expiration of the term, sale, or transfer of the land, and the purchaser or transferee shall assume the rights and obligations of the former landholder.

  2. On the validity and enforceability of the Kasunduan dated 28 September 1994

    The Court affirmed the declaration of nullity of the Kasunduan due to the legal incapacity of Librada Mauricio who was illiterate, did not fully understand the contents of the document, and was allegedly coerced into signing it.

  3. On the legal standing of Leonida

    The Court ruled that Leonida's status as a legal heir cannot be attacked collaterally in this proceeding, and upheld her substitution of Librada Mauricio in the case.

PRINCIPLES:

  1. Tenancy Relationship

    • A tenancy relationship persists despite the expiration of the leasehold contract or sale of the property. The new owner assumes the obligations of the previous owner.

  2. Nullity of Contracts

    • Contracts signed under duress or without proper understanding by an illiterate party, particularly when misrepresented, may be declared null and void.

  3. Collateral Attack on Filiation

    • Filiation or the status of being a legal heir cannot be questioned in a collateral proceeding but must be attacked directly through a proper legal action.