Bayani Bautista vs.

Patricia Araneta Bayani

G.R. No. 135829 (February 22, 2000)

Facts:
In essence, the plaintiff averred that he had been the lawful tenant of a three (3)
hectare parcel of land owned by Gregorio Araneta II since 1978. In April 1991, a group
of armed security guards, allegedly, were sent by herein defendant Patricia Araneta,
successor of Gregorio Araneta II and warned plaintiff to vacate and to stop cultivating the
subject landholding. Plaintiff prayed for the issuance of a temporary restraining order to
enjoin the defendant from the continued employment of threats and harassments against
his person, for the issuance of a permanent preliminary injunction during the pendency of
the case, for the maintenance of status quo and for the recognition of his right as tenant of
the land. Defendant to summarize, denied all the allegations of the plaintiff and stated
that the property belonged to Consuelo A. de Cuesta Auxilum Christianorum Foundation
Incorporated and leased to defendant for the development of a bio-dynamic farm and
ultimately for the establishment of a training center for bio-dynamic agriculture in the
Philippines and humid tropics in Asia. The land also does not fall under CARL because it
has more than 18% slope. During an ocular inspection, defendant learned of the presence
of the plaintiff. The former invited the latter to join the project but he declined and agreed
to leave the premises. However, the plaintiff changed his mind and refused to leave.
Efforts at conciliation did not push through and instead a Complaint for Peaceful
Possession with prayer for the issuance of a Temporary Restraining Order and Writ of
Preliminary Injunction was filed by the plaintiff.
Petitioner contends that in 1978, he entered into an oral tenancy agreement with
Gregorio Araneta II whom he has known and believed as the owner of the land. And that
he regularly delivered to Gregorio forty (40) cavans from the harvest through Lino Tocio.
Petitioner, likewise relies on the certification (ARPT and MARO) that he is a tenant on
the landholding.
Issue:
Whether or not the petitioner is a lawful tenant of the subject landholding
Held:
"His reliance on the certifications issued in his favor is misplaced because they do not
prove that the landowner made him his tenant. As the Court of Appeals aptly observed,
they only show that petitioner is in possession of the land. The certifications do not
disclose how and why he became a tenant." Lastly, we cannot sustain petitioner's
argument that he is a tenant by virtue of the factual finding of the DARAB. As discussed
above, DARAB mainly relied on the certifications issued in favor of petitioner in holding
that he is a tenant in the disputed landholding. In Oarde vs. Court of Appeals, we held
that certifications issued by administrative agencies or officers that a certain person is a
tenant are merely provisional and not conclusive on the courts. This Court is not
necessarily bound by these findings especially if they are mere conclusions that are not
supported by substantial evidence.