HEIRS OF JUGALBOT v CA

G.R. No. 170346

Facts:

On September 28, 1997, an Emancipation Patent (EP) was issued to Nicolas Jugalbot based on
the latter’s claim that he was the tenant of Lot 2180-C located at Barangay Lapasan, Cagayan de Oro
City. The subject property was registered in the name of Virginia A. Roa under Transfer Certificate of
Title (TCT) No. T-11543, the same being issued on April 1, 1970 in the name of "Virginia A. Roa
married to Pedro N. Roa." Nicolas Jugalbot alleged that he was a tenant of the property continuously
since the 1950s. On a Certification dated January 8, 1988 and issued by Department of Agrarian Reform
(DAR) Team Leader Eduardo Maandig, the subject property was declared to be tenanted as of October
21, 1972 and primarily devoted to rice and corn.

On August 10, 1998, the heirs of Roa filed before the DARAB Provincial Office of Misamis
Oriental a Complaint for Cancellation of Title, Recovery of Possession and Damages against Jugalbot.

ISSUE/S:

Whether or not a tenancy relationship exists between the Heirs of Nicolas and Roa

HELD:

NO. The fact alone of working on another’s landholding does not raise a presumption of the
existence of agricultural tenancy. Other factors must be taken into consideration like compensation in the
form of lease rentals or a share in the produce of the landholding involved. Without the essential elements
of consent and sharing, no tenancy relationship can exist between the petitioner and the private
respondents.

Bejasa v. Court of Appeals likewise held that to prove sharing of harvests, a receipt or any other
evidence must be presented as self-serving statements are deemed inadequate. Proof must always be
adduced.