Facts:

In the case of Alfonso Angliongto, Jr. vs. The Honorable Court of Appeals, et al. (G.R. No. L-48547), the petitioner-appellant, Alfonso Angliongto, Jr., sought a review of the decision made by the Court of Appeals which reversed a ruling by the Court of Agrarian Relations in Davao City. The case involved a 32-hectare land originally owned by Bernardo Geverola, who passed away, and whose estate was settled, declaring his son Isidoro Geverola as the sole heir. After Isidoro's demise, Angliongto, who had a substantial claim against Isidoro, foreclosed on the property and purchased it at a mortgage auction. Respondents included the heirs of both Bernardo and Isidoro, specifically Jesus Geverola, Jose Geverola (now deceased), Felisa Geverola, and Marcelo Capuno, all of whom claimed tenant rights to the land, stating they were agricultural tenants of the Geverola family and thus had a right of preemption.

The agrarian court found that these respondents were not tenants but simply

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Facts:

Background of the Case

• The dispute involves a 32-hectare coconut land originally owned by Bernardo Geverola.
• Upon Bernardo’s death, his estate was settled in Special Proceedings No. 4 of the Court of First Instance of Davao del Sur, declaring his only child, Isidoro Geverola, as the sole heir.
• After Isidoro’s subsequent death, his estate was settled in Special Proceedings No. 55 in Davao City, where the petitioner, Alfonso Angliongto, Jr.—also the holder of a P45,000.00-plus credit secured by a mortgage on the property—became the judicial administrator and later the purchaser at the mortgage-foreclosure auction.

The Auction and Acquisition

• Due to the unpaid indebtedness, the mortgage on the property was foreclosed, and at the auction sale, petitioner Angliongto emerged as the sole bidder and purchaser for the amount of the indebtedness.
• The transaction gave rise to a conflict regarding the possession and ownership of the property, notably involving the alleged right of preemption.

Dispute Over Preemption Rights

• The respondents (Jesus Geverola, Jose Geverola, Felisa Geverola, and Marcelo Capuno—whose wife is Luisa Geverola) contended that they had a right of preemption on the portions of the land on which they actually worked.
• They asserted that they were not mere trespassers but agricultural tenants under the ambit of Section 6 of Republic Act 1199 (Agricultural Tenancy Act), entitling them to purchase the land over the petitioner.
• The contention was that, as agricultural tenants, their longstanding occupation and cultivation provided them a legal interest in the land.

Evidence and Testimonies

• A report by the Commission established specific areas and coconut counts assigned to each respondent:
• Jesus Geverola had about 4 hectares with various ages of coconuts.
• Jose Geverola worked on 1.5 hectares with documented coconut plantings.
• Felisa Geverola and Marcelo Capuno (with additional counts and assignments) were similarly detailed in the report.
• Testimonies revealed that the respondents were taken in as orphans by Bernardo Geverola, who cared for them as his own children.
• The record shows that from a very young age, these close relatives were provided with schooling, sustenance, and eventually, specific land assignments for cultivation as they grew older.

Nature of the Working Arrangement

• Bernardo Geverola’s actions were characterized by compassion and familial duty rather than a formal tenancy contract.
• As the respondents matured, Bernardo assigned each a portion of land to work—not in the capacity of formal tenants but as members of a family who were expected to help in the agrarian enterprise.
• The division of proceeds (typically a 75%-25% share in favor of the respondents) was considered a special favor rather than evidence of an agreement to a tenancy relationship.

Withdrawal of Other Claims

• Evidence of various defendants’ withdrawals from the case (e.g., affidavits and documents from Felipe Galeos, Gaudencio Geverola, Venancia Saavedra Vda. de Kintanar, Genaro Geverola, Miguel Kintanar, and others) further underscored that many did not affirm a tenancy relationship.
• These withdrawals indicate that Bernardo Geverola’s arrangements were not universally understood or accepted as constituting an agricultural tenancy.

Issue:

• Whether or not the respondents (the close relatives and assigned landworkers) should be characterized in law as agricultural tenants under Section 6 of Republic Act 1199.
• In the event that they are characterized as agricultural tenants, whether they are entitled to the statutory right of preemption over the petitioner, who acquired the property at auction.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)