Rodriguez v Salvador

DEL CASTILLO, J.:

Facts: Salvador filed a Complaint for Unlawful Detainer against Rodriguez. Salvador alleged that she is
the owner of a parcel of land, that Rodriguez acquired possession of the subject land by mere
tolerance of her predecessors-in-interest; and despite several verbal and written demands Rodriguez
refused to vacate. Rodriguez claims that they entered the land with the consent under the agreement
that they would devote the property to agricultural production and share the produce with the
Salvador siblings.

Issues: WHETHER RODRIGUEZ ARE NOT TENANTS OF THE SUBJECT LAND.

Rulling: Agricultural tenancy relationship does not exist. It exists when 1) the parties are the
landowner and the tenant or lessee; 2) the subject is an agricultural land; 3) there is consent between
the parties; 4) the purpose is to bring agricultural production; 5) there is personal cultivation on the
part of the tenant or lessee; and 6) the harvest is shared between landowner and tenant or lessee.
The statements in the affidavits presented by the petitioners are not sufficient to prove the existence
of an agricultural tenancy. The element of consent and sharing of harvest is lacking. No other evidence
was submitted to show that respondent's predecessors-in-interest consented to a tenancy
relationship. Self-serving statements will not prove consent of the landowner. Mere occupation or
cultivation of an agricultural land will not make the tiller an agricultural tenant. It must be proved by
substantial evidence the requisites of agricultural tenancy.