Evangelista vs.

Court of Appeals
G.R. No. L-37736
February 23, 1988
Topic: Elements of Tenancy Relation
Fact:
The Petitioner
The Private Respondent is the owner of a 5-hectare land occupied by the petitioner.
The Petitioner filed a case against the Private respondent for being unlawfully ejected to said land. He
was alleging that he was a tenant for a long time therefore he cannot be ejected right away.
The Private respondent argued that that the land was voluntarily surrendered by the petitioner upon
expiration of the civil lease over the land. The said arguments were supported by different document
signed by both parties.
The petitioner argued that it was a agricultural lease and not a civil lease.
Issue:
Is there a Tenancy relationship between the parties?
Held:
No, in order to determine if there is a tenancy relationship between the parties we must determine first
what kind of lease is established between the parties. In accord to finding of the court it is a civil lease
and not an agricultural lease. It is clear in the face of the contract that was entered into by both parties
it was civil lease. It was not even stipulated in the contract that the petitioner should actually cultivate
the land therefore it is clear that it was not the intent of the parties to enter an agricultural lease.