Title
Ambayec vs. Court of Appeals
Case
G.R. No. 162780
Decision Date
Jun 21, 2005
Petitioners claimed tenancy over land bulldozed by respondents; Supreme Court ruled no tenancy relationship existed due to insufficient evidence of consent, sharing, or cultivation.
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Case Digest (G.R. No. 162780)

Facts:

  1. Parties Involved:

    • Petitioners: Sofronio Ambayec, represented by his heirs, and other family members.
    • Respondents: Heirs of Vicente and Vicenta Tionko.
  2. Background of the Dispute:

    • Sofronio Ambayec and Damian Alicabo claimed to have been tenants of the Tionko spouses since 1930 and 1924, respectively.
    • In 1975, 13 out of 24 hectares of land they occupied were bulldozed by the Tionkos, destroying crops and trees.
    • The land was subdivided and sold to various buyers without compensation or disturbance payment to the petitioners.
  3. Legal Proceedings:

    • The case was initially filed before the Court of Agrarian Relations (CAR) in Davao City.
    • The respondents argued that the CAR lacked jurisdiction because the land was reclassified as residential in 1961.
    • The case was transferred to the Regional Trial Court (RTC) and later to the Department of Agrarian Reform Adjudication Board (DARAB) under Republic Act No. 6657.
    • The DARAB ruled in favor of the petitioners, declaring Sofronio Ambayec and his father as bona fide tenants and ordering the respondents to maintain their peaceful possession of the remaining 10 hectares.
    • The Court of Appeals reversed the DARAB decision, ruling that no tenancy relationship existed.
  4. Petitioners' Claims:

    • Sofronio Ambayec had been in continuous possession of the land since time immemorial.
    • Vicente Tionko claimed ownership and forced Sofronio to share the produce due to his influence.
    • After the Tionkos' death, the land was transferred to Maria Judith Tionko, whose husband bulldozed the crops.
  5. Evidence Presented:

    • Certifications from the Bureau of Lands and the Ministry of Agrarian Reform (MAR) recognizing Sofronio as a tenant.
    • Affidavits from the petitioners claiming tenancy.

Issue:

  1. Whether the Court of Appeals erred in reversing the DARAB decision.
  2. Whether Sofronio Ambayec and his heirs were tenants of the Tionkos.
  3. Whether Presidential Decree No. 27 (Land Reform Program) applies to the case.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court upheld the Court of Appeals' decision, ruling that the petitioners failed to prove the existence of a tenancy relationship with the Tionkos. The certifications and affidavits presented were insufficient to establish the essential elements of tenancy, and the petitioners' claims were inconsistent and unsupported by evidence.


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