G.R. No.

108941, July 6, 2000

Reynaldo Bejasa and Erlinda Bejasa
vs CA, Isabel Candelaria and Jamie Dinglasan
Ponente: Pardo

Facts:
This case involves two parcels of land located in Oriental Mindoro owned by Isabel Candelaria.
October 1974, Candelaria entered into a 3-year lease agreement with Pio Malabanan wherein
Malabanan agreed to clear, clean and cultivate the land, to purchase calamansi, and other
seedlings, to attend and care for whatever plants thereon exist, to make the necessary harvest of
fruits.

Malabanan, later hired the Bejasas to plant on the land and to clear it. On May 1977, Candelaria
gave Malabanan a 6-year usufruct over the land. 1983, Malabanan died. Candelaria constituted
Jaime Dinglasan as her attorney-in-fact, having powers of administration over the land.

October 1984, Candelaria entered into a new lease contract with Victoria Dinglasan, Jaime's wife
with a 1-year term. On December 1984, Bejasas agreed to pay Victoria rent in consideration of
an "pakyaw na bunga" agreement, with a term of 1 year.

After the 1 year period, Victoria demanded for Bejasas to vacate, but Bejasas continued to stay
and did not give any consideration for its use, be in rent or share. Candelarian again entered with
a 3-year lease agreement with Dinglasans, and made Jaime her attorney-in-fact again. Jaime then
filed a complaint before Commission on the Settlement of Land Problems (COSLAP) seeking
for ejectment of Bejasas. COSLAP dismissed the complaint.

Jaime then filed it with RTC for recovery of possession; the case was referred to DAR. DAR
certified that ht e case was not proper for trial before the civil courts. Trial court dismissed the
complaint of Jaime including the leasehold claim of Bejasas. Bejasas then filed a complaint for
confirmation of leasehold and recovery of damages against Candelaria and Jaime.

RTC favored the Bejasas. On appeal, CA reversed the decision saying that (1) there was no
tenant relationship, (2) Bejasas are mere overseers and not as permanent tenants, (3) the pakyaw
contract have expired, (4) sharing of profits was not proven, (5) the element of personal
cultivation was not proven.

Issue: Whether there is tenancy in favor of Bejasas.

Ruling:

There is no tenancy relationship. There was no proof of shared harvests. Between Candelaria (as
owner) and the Bejasas, there is no relationship. Candelaria never gave her consent. As to the
authority of Dinglasans, they had authority to bind the owner in a tenancy agreement, but there is
no proof of such presented.