I am aware of the equivalence of the particules の and が in the case of a relative clause (cf. for instance How does the の work in 「日本人の知らない日本語」?).
However, the following haiku does not seem to fall into this category:
枯枝に 烏のとまりけり 秋の暮
Does the use of の bring a special nuance here? One answer on Why is the particle の used instead of が in these phrases? suggests that it could shift the focus on the verb/action rather than on the subject, but given the use of the auxiliary けり that describes the action as completed, this would be a very subtle nuance.
