The Supreme Court denied the petition and ruled that no tenurial relationship existed between the petitioners and respondent. It found that the affidavits submitted by petitioners were not sufficient to prove the elements of an agricultural tenancy, particularly consent by the landowner. While petitioners cultivated the land and shared harvests for decades, there was no independent evidence showing the landowner agreed to an agricultural tenancy. The respondent was entitled to fair rental compensation for petitioners' occupation of the land.
The Supreme Court denied the petition and ruled that no tenurial relationship existed between the petitioners and respondent. It found that the affidavits submitted by petitioners were not sufficient to prove the elements of an agricultural tenancy, particularly consent by the landowner. While petitioners cultivated the land and shared harvests for decades, there was no independent evidence showing the landowner agreed to an agricultural tenancy. The respondent was entitled to fair rental compensation for petitioners' occupation of the land.
The Supreme Court denied the petition and ruled that no tenurial relationship existed between the petitioners and respondent. It found that the affidavits submitted by petitioners were not sufficient to prove the elements of an agricultural tenancy, particularly consent by the landowner. While petitioners cultivated the land and shared harvests for decades, there was no independent evidence showing the landowner agreed to an agricultural tenancy. The respondent was entitled to fair rental compensation for petitioners' occupation of the land.
Contents • Facts of the Case • Issue(s) • Petitioner’s and Respondent’s Arguments • Lower Court’s Ruling • SC Ruling COMPLAINT (Plaintiff) • In 2003, respondent Salvador filed a complaint for Unlawful Detainer against petitioners Rodriguez before MTC Dalaguete Cebu • Cause of Action: – Respondent is the absolute owner of a parcel of land – Petitioner acquired possession of it ANSWER (Defendant) • DEFENSE OF AGRICULTURAL TENANCY – Petitioners entered but with consent – Agreement was to devote property to agricultural production and production sharing – Tenancy relationship exists • LACK OF JURISDICTION BY MTC – Since TR exists, DARAB has jurisdiction, not MTC MTC RULING • Complaint Dismissed on Lack of Jurisdiction – TR exists thru consent by P-I-I and binds the respodents – Tenurial arrangement is inferred from respondents by receiving share of the harvests – Dispossession of agricultural tenants can only be ordered by Court for causes expressly provided under Sec. 36 of R.A. 3844 – MTC has no jurisdiction over UD cases involving agricultural tenants – DARAB has primary and exclusive jurisdiction RTC RULING • MTC Decision is affirmed – Same ratio as MTC CA RULING • RTC decision is set aside. – No TR exists – Petitioners’ witnesses’ testimony are insufficient to establish status as agricultural tenants – Affidavits merely showed that petitioners are occupying the subject land with the consent of the original owners – Since petitioners are tolerated by mere tolerance, they are bound by an implied promise to vacate the same upon demand – Petitioners are likewise liable to pay damages ISSUES RESOLVED • W/N CA acted with grave abuse of discretion in ruling that petitioners are not tenants of the subject land • W/N the CA ruling has factual and legal basis and is supported with substantial evidence PETITIONER’S ARGUMENTS • Sec. 5 of R.A. 3844, tenancy may be constituted by agreement of the parties either orally or in writing, expressly or impliedly. • There was implied consent since respondents’ P-I-I allowed them to cultivate the land and share the harvest for more than 40 years • CA also erred in disregarding affidavits of witnesses who had personal knowledge of the cultivation and sharing of harvest RESPONDENT’S ARGUMENTS • Petitioners are not agricultural tenants because mere cultivation of an agricultural land does not make the tiller an agricultural tenant • Respondents’ P-I-I merely tolerated occupation of the subject land SC RULING • Petition is DENIED. – Agricultural tenancy relationship does not exist in this case. – Respondent is entitled to the fair rental value or the reasonable compensation for the use and occupation of the subject land SC RULING • NO TR exits. (Elements) 1. Parties: Landowner/Agri Tenant 2. Subject Matter: Agri land 3. Consent 4. Purpose: Agri Production 5. Personal cultivation on tenant 6. Shared Harvest SC RULING • Petitioners submitted evidence to prove TR exists thru petitioner and her neighbour’s affidavits – Agreed to agri production plus 50-50 shared harvest and watch over the land – Cultivation is since 1960 • Statements in the affidavits are not sufficient to prove existence of Agri tenancy • Consent is lacking • No other evidence is submitted to show that respondents’ P-I-I consent to the Agri Tenancy • Independent evidence is necessary SC RULING • Petitioners submitted evidence to prove TR exists thru petitioner and her neighbour’s affidavits – Agreed to agri production plus 50-50 shared harvest and watch over the land – Cultivation is since 1960 • No consent was given. • Sharing of harvest is not proved. – Must have presented receipts or any other evidence • Independent evidence is necessary contrary to self- serving affidavits of petitioners • Mere occupation or cultivation of agri land will not ipso facto make the tiller and agri tenant SC RULING • Respondent is entitled to fair rental value as reasonable compensation – Respondent may only recover the fair rental value or the reasonable compensation for the use and occupation of the leased property