Suplico v.

CA: Requisites present

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Suplico is a lessee of rice land

Private respondent was allowed by Suplico to till the land while Suplico will provide
the farm implements and thereafter Suplico was to receive cavans from the palay by
way of rental
Years later, Suplico threatened to eject priv. resp. from the property
So private respondent filed an action for damages against Suplico in CAR
Resp. Owner intervened in case and alleged the absence of contractual relationship
Trial Court declared private respondent as agricultural lessee and confirmed by CA

SC: No reasons to disturb findings

Private respondent was in actual possession of land with family in a farmhouse just like
what a farm tenant normally would. Private respondent and his wife were personally plowing,
plowing, planting and harvesting. The occasional and temporary hiring of persons outside the
immediate household, so long as the tenant himself had control in the farmwork, was not
essentially opposed to the status of tenancy. Management was left entirely to private respondent
who defrayed the cultivation expenses. Private respondent shared the harvest with Suplico, the
licensed ricemiller of Tarlac, attested to Suplicos having received from private respondent the
cash value of the rental payments from the first crop of 1979 and each crop thereafter up the
first crop of 1983, inclusive. The rental payments made thereafter were received by petioner
Lolita Suplico, court appointed police officers or the barangay.

Monsanto v. Zerna
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Petitioner is claiming the amoung of Php 1,100 as balance from the proceeds of copra
sale.
Private respondents contend that this Php 1,100 is their compensation pursuant to
tenurial arrangements.
Since this amount is intertwined with the resolution of agrarian dispute. CA correctly
ruled that DARAB has jurisdiction.
RTC has only jurisdiction over criminal and it acted beyond when it ruled agri
tenancy between parties. This belongs to DARAB.
Tenanct replationship may be established verbally or writing, expressly or impliedly.
o Here there was agreement which contradicts petitioners contention that
private respondents are mere overseers. Being overseers does not foreclose
their being tenants.
o (1) petitioner allowed respondents to plant coconut, etc.
o (2) harvests: receipts of remittance by respondent

Bejasa v. CA: Tenancy not established

FACTS:

Candelaria owned two parcels of land, which she leased to Malabanan.

Malabanan hired the Bejasas to plant on the land and clear it, with all the expenses
shouldered by Malabanan.
Bejasas continued to stay on the land and did not give any consideration for its use,
be it in the form of rent or a shared harvest

ISSUE: Whether or not there is a tenancy relationship in favor of the Bejasas

SC:
Court found that there was no tenancy relationship between the parties. There was
no proof that Malabanan and the Bejas shared the harvests. Candelaria never gave her
consent to the Behasas stay on the land. There was no proof that the Dinglasans gave
their authority to the Bejasas to be the tenant of the land in question. Not all the elements
of tenancy were met in this case.
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No proof of sharing in harvest

o While Bejasa testified, SC said only Bejasas word was presented to prove
this. Besides the testimony was suspicious because of inconsistency. Bejasa
testified that he agreed to deliver 1/5 of harvest as owners share, yet all at one
time, he also mentioned that 25% was for Malabanan and 50% for the owner.
Landowners never gave consent
o Citing Chico v. CA self serving statement are inadequate proof must be
adhered; to prove sharing of harvests, a receipt or any other similar evidence
must be presented, self-serving statements are inadequate.
o Even assuming that landowner agreed to lease it for Php 20,000 per year, such
agreement did not prove tenancy. Consideration should be harvest sharing.

Valencia v. Court of Appeals

Question: Can a contract of civil law lease prohibit a civil law lessee from employing a
tenant on the land subject matter of the lease agreement?
SC:
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An allegation that an agricultural tenant tilled the land in question does not make the
case an agrarian dispute. The elements of tenancy must be first proved in order to
entitle the claimant to security of tenure.
A tenancy relationship cannot be presumed. With respect to the lease agreement
between Valencia and Fr. Flores, the lessee did not have any authority to sublease
Valencias property due to the prohibition in their lease must be so specifically
authorized.
A different interpretation would create a perverse and absurd situation where a person
who wants to be a tenant, and taking advantage of this perceived ambiguity of the
law, asks a third person to become a civil law lessee of the landowner. Incredibly, this
tenant would technically have a better right over the property than the landowner
himself.

Almuete v. Andres: About Ownership

FACTS:
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Almuete was in exclusive possession of the subject land

Unknown to Almuete, Anderes was awarded homestead patent due to investigation
report that Almuete was unknown and waived his rights. Andres also represented that
Almuete sold the property to Masiglat for radiophone set and that Masiglat sold it to
him for a carabao and Php 600.
Almuete filed an action for recovery of possession and reconveyance before the trial
court.

ISSUE:
Who between 2 awardees of lot has better right to the property?
SC:
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This is a controversy relating to ownership of farmland so, beyond the ambit of

agrarian dispute
No juridical tie of landowner and tenant was alleged between petitioners and
respondent.
RTC was competent to try the case.

Pasong Bayabas v. CA: Tenancy not established

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Development of land: converted from agricultural to residential as approved by DAR

Petitioners, claimed being actual tillers of land, filed complaint for damages alleging
surreptitious conversion; priv. respondent denied cultivation; waiver of rights was
executed by some

SC: no tenancy no evidence

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No allegation in complaint that petitioners-members are tenant; waiver of rights

constitutes abandonment
No substantial evidence that private respondent is landlord
No possession and entry is w/o knowledge of owner

Escariz v. Revilleza: Tenancy not established

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Involving an orchard owned by private respondents

Petitioner is claiming tenancy; private respondent denied it, saying that petitioner is
actually a tenant of the owner of a neighboring Riceland and petitioner illegally
entered the property by erecting a shack where he lives.
DARAB considered petitioner as tenant; CA reversed.

SC: Tenancy is not presumed:

No evidence to prove consent of parties and sharing of harvest

SC agreed with CA that there is no evidence on record to prove the existence of the
following elements: (a) the consent of the parties and (b) the sharing of harvest.
Other than the self-serving statement of petitioner that he is a tenant, there is no
concrete evidence to show that the parties agreed to establish such a relationship.
Anen the sharing of harvests, again there is no evidence to prove this element (citing
Bejasa v. CA)

Hiers of Jugalbot v. CA: Tenancy not established

FACTS:
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In 1997, Jugalbot was issued Emancipation Patent based on his claim that he was the
tenant;
EP was challenged by heirs of priv. resp. before DARAB and seek cancellation of the
title in the name of Jugalbot and recovery of possession; DARAB Prov. Adjudicator
dismissed the complained and on appeal, DARAB Central Office upheld;
CA reversed on, among others, absence of tenancy relationship.

SC:
Absence of tenancy relationship.
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Taking of property violated due process (CA was correct in pointing out that Virginia
A. Roa was denied due process because DAR failed to send notice of the impending
land reform coverage to the proper party); no ocular inspection or any on-site factfinding investigation and report to verify the truth of the allegations of Nicolas
Jugalbot that he was a tenant of the property;
No concrete evidence of cultivation; No proof was presented except for their selfserving statements
o Independent evidence, aside from self-serving statements, is needed.
o Plus CA findings Jugalbot was soldier of US Army and migrated to US and
returned only in 1998, wife and daughter were residents of California.
Land involved is residential and not agricultural because of zoning ordinance.

Nicorp Management and Devt Corp. v. De Leon: Tenancy not shown

SC:
There is no substantial evidence to support the appellate courts conclusion that
respondent is a bona fide tenant on the subject property. Respondent failed to prove the third and
sixth elements cited above. It was not shown that the de Leon sisters consented to a tenancy
relationship with respondent who was their sister-in-law, or that the de Leon sisters received any
share in the harvests of the land from respondent or that the latter delivered a proportionate
share of the harvest to the landowners pursuant to tenancy relationship.