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FERDINAND A. DELA CRUZ v. AMELIA G. QUIAZON

FACTS:

The case involves petitioners Ferdinand and Renato dela Cruz seeking the review of the Court of Appeals Decision affirming the Department of Agrarian Reform Adjudication Board (DARAB) Resolution canceling the Certificate of Land Transfer (CLT) in the name of their father, Feliciano dela Cruz, and directing them to vacate the property.

The case arose from a dispute over a parcel of land covered by Transfer Certificate of Title (TCT) No. 107576, which was brought under the coverage of Operation Land Transfer pursuant to Presidential Decree (P.D.) No. 27. On June 8, 1981, Feliciano dela Cruz, a tenant-farmer, was issued CLT No. 0-036207 over a portion of the said property.

The heirs of the registered owner later executed a Deed of Extrajudicial Admission and Partition with Waiver, adjudicating the properties among themselves except for the subject property, which was adjudicated solely in favor of respondent Amelia G. Quiazon.

In 1993, respondent filed a complaint against petitioner Ferdinand dela Cruz alleging non-payment of rent and abandonment of the land. Petitioners argued that by virtue of the CLT, they became the owners of the landholding and only had to pay amortizations to the Land Bank of the Philippines.

The case went through several proceedings, including an appeal by respondent and the grant of an application for retention by the heirs of the registered owner. The DARAB eventually set aside its earlier decision, dissolved the tenancy relationship, canceled the CLT, and ordered petitioners to vacate the land. The Court of Appeals affirmed the DARAB decision, prompting the petitioners to file this petition for review on certiorari.

ISSUES:

  1. Whether there was a basis for the grant of the petition for relief from judgment.

  2. Whether the respondent had legal standing to file the petition for relief from judgment.

  3. Whether the DARAB erred in granting the petition for relief from judgment.

  4. Whether or not the DARAB erred in granting the petition for relief from judgment;

  5. Whether or not the issuance of a Certificate of Land Transfer (CLT) vests full ownership in the holder;

  6. Whether or not the petitioners have abandoned the subject landholding;

  7. Whether or not the cancellation of a CLT is within the jurisdiction of the DARAB;

  8. Whether or not the DAR Secretary has the authority to cancel the CLT issued to tenant-beneficiaries.

  9. Whether a corporation can be held liable for indirect contempt of court.

  10. Whether said corporation is guilty of indirect contempt.

RULING:

  1. The Court held that there was no basis for the grant of the petition for relief from judgment. A petition for relief from judgment is an equitable remedy that is allowed only in exceptional cases when there is no other available or adequate remedy. It is not available to parties who have another remedy available, such as a motion for new trial or an appeal, and who were not prevented by fraud, accident, mistake, or excusable negligence from availing themselves of such remedy. In this case, the respondent's failure to avail herself of a motion for reconsideration or an appeal to the CA was due to her own negligence, which cannot be excusable. She had knowledge of the DARAB decision and even engaged the services of a new counsel in a separate case, showing that she knew how to pursue legal remedies.

  2. The Court affirmed the respondent's legal standing to file the petition for relief from judgment. The personality to file a petition for relief from judgment resides in a person who is a party to the principal case, and this legal standing is not lost by the mere transfer of the disputed property during the proceedings.

  3. The Court held that the DARAB erred in granting the petition for relief from judgment. The respondent's negligence in failing to file a motion for reconsideration or an appeal from the DARAB decision was not excusable. Relief will not be granted to a party who seeks to avoid the effects of a judgment when the loss of the remedy at law was due to their own negligence. The petition for relief from judgment cannot be used to revive the right to appeal that was lost through inexcusable negligence.

  4. The DARAB erred in granting the petition for relief from judgment.

  5. The issuance of a CLT does not vest full ownership in the holder. It merely evinces that the grantee is qualified to avail of the mechanism for the acquisition of ownership.

  6. The petitioners have not abandoned the subject landholding.

  7. The cancellation of a CLT is within the jurisdiction of the DAR Secretary, not the DARAB.

  8. The DAR Secretary has the authority to cancel the CLT issued to tenant-beneficiaries.

  9. Yes, a corporation can be held liable for indirect contempt of court.

  10. In this case, the corporation is found guilty of indirect contempt for its failure to comply with a court order to pay the monetary award to the plaintiff.

PRINCIPLES:

  • A petition for relief from judgment is an equitable remedy that is allowed only in exceptional cases when there is no other available or adequate remedy. It cannot be availed of by a party who has another remedy available, such as a motion for new trial or an appeal.

  • Negligence to be excusable must be one which ordinary diligence and prudence could not have guarded against.

  • The legal standing to file a petition for relief from judgment resides in a person who is a party to the principal case, and this standing is not lost by the mere transfer of the disputed property during the proceedings.

  • The issuance of a CLT does not sever the tenancy relationship between the landowner and the tenant-farmer.

  • Abandonment requires a clear and absolute intention to renounce a right or claim and an external act expressing or carrying out that intention.

  • The cancellation of a CLT is within the jurisdiction of the DAR Secretary, not the DARAB.

  • The DAR Secretary has the authority to cancel the CLT issued to tenant-beneficiaries.

  • A corporation can be held liable for indirect contempt of court.

  • Failure to comply with a court order can be considered indirect contempt.

  • Contempt of court may be punished with a fine or imprisonment, or both.