The Supreme Court in Heirs of Exequiel Hagoriles v. Romeo Hernaez, et al. ruled that the obligation to provide home lots to agricultural tenants rests solely on the landholder who directly employs them, not on subsequent transferees of portions of the land. This decision clarifies that only tenants of a specific landholder are entitled to home lots within that landholder’s property, ensuring that landowners are not unduly burdened by obligations to tenants they do not directly employ. This distinction is crucial in determining the scope of agrarian reform benefits and responsibilities.

Who Pays the Rent? Tracing Landowner Obligations in Agrarian Disputes

This case revolves around a dispute over home lots between the heirs of Exequiel Hagoriles and several respondents claiming to be agricultural tenants. The core legal question is whether the petitioners, as transferees of a portion of land, are obligated to provide home lots to tenants who were originally under a different landholder. This dispute highlights the complexities of agrarian reform, particularly the rights and obligations of landowners and tenants in the context of land ownership transfers.

The factual backdrop involves several individuals who have been tenant-tillers on lands in Negros Occidental since 1967. They occupied not only their tillage areas but also individual home lots on a separate parcel of land. This parcel, designated as Lot No. 2047, was originally registered under Engracia Ramos, the spouse of Timoteo Ramos, who was the landholder for most of the respondents. In 1990, Exequiel Hagoriles purchased a portion of Lot No. 2047 from Amparo Ramos-Taleon, daughter of Timoteo Ramos. This purchase set the stage for the legal battle, as Hagoriles later sought to eject one of the tenants, leading to a complaint filed with the Provincial Agrarian Reform Adjudicator (PARAD).

The PARAD initially ruled in favor of some tenants, finding them to be lawful tenants entitled to peaceful possession of their home lots, based on emancipation patents and lease rental payments. However, the Department of Agrarian Reform Adjudication Board (DARAB) later expanded this ruling, declaring all the respondents to be bona fide tenants of their respective landholdings. The DARAB discovered that EPs were soon to be issued to the remaining respondents, confirming their status as tenant-beneficiaries under the Comprehensive Agrarian Reform Program (CARP). Despite this finding, the DARAB declined to rule on the entitlement to home lots, considering it a matter outside their jurisdiction.

The case eventually reached the Court of Appeals (CA), which affirmed the DARAB’s finding that the respondents were bona fide tenants. The CA also held that the petitioners, as transferees of Lot No. 2047, were bound by the tenancy relations between the respondents and the previous owners. Thus, the CA ordered the petitioners to maintain the respondents’ peaceful possession of their home lots. The CA reasoned that a home lot is incidental to a tenant’s rights, making its determination a proper agrarian dispute within the DARAB’s jurisdiction.

However, the Supreme Court disagreed with the Court of Appeals’ decision, finding merit in the petition. The Supreme Court emphasized that the obligation to provide home lots rests upon the landholder, citing Section 26(a) of R.A. No. 1199, as amended by R.A. No. 2263. This provision explicitly states:

Sec. 26. Obligations of the Landholder:

(a) The landholder shall furnish the tenant with a home lot as provided in section 22 (3): Provided, That should the landholder designate another site for such home lot than that already occupied by the tenant, the former shall bear the expenses of transferring the existing house and improvements from the home lot already occupied by the tenant to the site newly designated by the former: Provided, further, That if the tenant disagrees to the transfer of the home lot, the matter shall be submitted to the court for determination.

The Court further clarified that under Section 22(3) of RA No. 1199, a tenant is entitled to a home lot suitable for dwelling with an area of not more than three percent (3%) of the area of his landholding, provided that it does not exceed one thousand square meters (1,000 sq.m.). It shall be located at a convenient and suitable place within the land of the landholder. Critical to the Court’s reasoning was the fact that the subject home lots were designated on a parcel of land separate from the farmlands cultivated by the respondents, and this parcel was originally registered under the name of Engracia Ramos, not Timoteo Ramos, the landholder for most of the respondents.

The Supreme Court highlighted the property relations of spouses Timoteo and Engracia Ramos, which were governed by the old Civil Code. Under Article 148 of the old Civil Code, the spouses retain exclusive ownership of property they brought to the marriage as his or her own. Since Lot No. 2047 was originally registered under Engracia’s name, it was presumed to be her paraphernal property, not conjugal property. The Court noted that in 1976, Lot No. 2047 became subject of estate settlement proceedings and was partitioned among Engracia’s heirs. Amparo Ramos-Taleon, Timoteo’s daughter, subsequently sold a portion of Lot No. 2047 (her share of the lot) to Ezequiel Hagoriles.

The Supreme Court concluded that because Timoteo Sr. merely owned a portion of Lot No. 2047, the CA erred in subjecting the entire lot for the use of the respondents’ home lots. Only Timoteo Sr., being the named landowner of most of the respondents’ landholdings, has the obligation to provide home lots to his tenants. There is no such obligation from the other co-owners of Lot No. 2047, including the petitioners who were transferees of Amparo’s share of the lot. This distinction is critical because it limits the obligation to provide home lots to the actual landholder-tenant relationship.

The Court clarified that only those respondents who are Timoteo’s tenants and whose home lots are located within Timoteo’s portion of Lot No. 2047 can be guaranteed the peaceful possession of their home lots. The other respondents, who are not tenants of Timoteo, or those who are Timoteo’s tenants but whose home lots do not fall within Timoteo’s share of Lot No. 2047, cannot be guaranteed continuous possession. The Court reiterated that the petitioners are not transferees of Timoteo Sr. but of Amparo, who is not a landholder of the respondents. Thus, the petitioners may not be compelled to maintain the home lots located within their acquired portion of Lot No. 2047. This part of the decision underscores the importance of establishing a direct landholder-tenant relationship for the obligation to provide home lots to arise.

The Supreme Court emphasized that the issue on the respondents’ entitlement to their home lots should be referred to the DARAB for proper determination, as it involves an agrarian dispute. The Court cited Section 3(d) of Republic Act No. 6657, otherwise known as the COMPREHENSIVE AGRARIAN REFORM LAW OF 1988, which defines an agrarian dispute as any controversy relating to tenurial arrangements. The right to a home lot is a matter arising from a landlord-tenant relationship, making it a proper subject for the DARAB’s jurisdiction. The Court also noted that if the respondents are found not entitled to possess their present home lots, they can demand from their landholders to designate another location as their home lot. This obligation continues as long as the tenancy relations exist and have not been severed. In essence, the Supreme Court’s ruling clarifies the specific responsibilities of landowners regarding home lots for agricultural tenants, ensuring that only those with a direct tenancy relationship are entitled to these benefits.

Finally, the Court addressed the parties’ alleged Compromise Agreement, ruling that it had no effect on the resolution of the case because it was never submitted for court approval. While parties to a suit may enter into a compromise agreement, it only has the force and effect of a judgment when it receives court approval. Since the agreement was not approved, it could not be enforced. However, the Court noted that the parties were not prevented from pursuing their compromise agreement or entering into another agreement, provided that their stipulations are not contrary to law, morals, good custom, public order, or public policy.

In conclusion, the Supreme Court’s decision in this case clarifies the scope of a landowner’s obligation to provide home lots to agricultural tenants. It underscores that this obligation rests primarily on the landholder who directly employs the tenants, not on subsequent transferees of portions of the land. This ruling ensures that landowners are not unduly burdened by obligations to tenants they do not directly employ and that agrarian reform benefits are appropriately allocated based on direct tenancy relationships.

FAQs

What was the key issue in this case?	The key issue was whether the heirs of a landowner who purchased a portion of land were obligated to provide home lots to tenants who originally worked for a different landholder. The Supreme Court clarified that this obligation rests solely on the original landholder, not the subsequent transferees.
Who is responsible for providing home lots to agricultural tenants?	The primary responsibility for providing home lots rests on the landholder who directly employs the agricultural tenants. This obligation is tied to the existence of a direct landlord-tenant relationship.
What happens if the land is transferred to a new owner?	If the land is transferred, the new owner is not automatically obligated to provide home lots to tenants who were originally under a different landholder, unless the new owner also becomes their landholder. The obligation remains with the original landholder.
What is the size and location of a home lot?	According to RA No. 1199, as amended, a tenant is entitled to a home lot suitable for dwelling, with an area of not more than three percent (3%) of the area of his landholding, provided it does not exceed 1,000 square meters. It should be located in a convenient and suitable place within the land of the landholder.
What is the role of the DARAB in these disputes?	The Department of Agrarian Reform Adjudication Board (DARAB) has jurisdiction over agrarian disputes, including controversies relating to tenurial arrangements and the right to a home lot. They are responsible for determining the rights of tenants and landholders in these matters.
What if the home lot is located on a different parcel of land?	If the home lot is located on a different parcel of land owned by someone other than the tenant’s landholder, the landowner of that parcel is not obligated to maintain the tenant’s possession of the home lot. The obligation rests with the tenant’s actual landholder.
What is the effect of a compromise agreement in such cases?	A compromise agreement intended to resolve a matter under litigation has the force and effect of a judgment only if it receives the approval of the court where the litigation is pending. Without court approval, the agreement cannot be enforced.
Can tenants demand a different home lot if they are not entitled to the current one?	Yes, if tenants are found not entitled to possess their current home lots, they can demand that their landholders designate another suitable location as their home lot, provided the tenancy relationship still exists.

This ruling offers critical guidance for landowners and tenants alike, particularly in scenarios involving land transfers and the enforcement of agrarian reform laws. It underscores the importance of establishing clear, direct tenancy relationships to ensure the appropriate allocation of rights and responsibilities.

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: Heirs of Exequiel Hagoriles v. Romeo Hernaez, et al., G.R. No. 199628, April 20, 2016