G.R. No. 98028 - Castillo vs. Court of Appeals

On July 18, 1985, respondent Alberto Ignacio filed a complaint for injunction against petitioner Gregorio Castillo before the Regional Trial Court of Malolos, Bulacan.
The complaint alleged that Ignacio was the agricultural tenant of Castillo’s parcel of land (9,920 square meters with fruit-bearing trees in Cut-cut, Pulilan, Bulacan), established through a written agreement or “Kasunduan” (Exhibit “C”).

The “Kasunduan” purported that, in a gesture of goodwill when Castillo sought permission to construct a rest house, Ignacio consented to allow it, which was then taken as establishing a tenancy relationship.
Castillo, however, contended that he never asked Rosario’s permission to build the rest house because as owner he had the right to do so; moreover, he argued that Ignacio was merely a “magsisiga” (smudger) rather than a bona fide tenant.
It was further alleged that Castillo violated the agreement by cutting some of the fruit-bearing trees and obstructing the area devoted to vegetable planting by filling it with adobe stones.

The Regional Trial Court on September 28, 1988, rendered a judgment declaring that no tenancy relationship existed between petitioner and respondent. The judgment:

It held that a tenancy relationship existed between the parties.
It permanently enjoined petitioner Castillo from disturbing respondent Ignacio’s peaceful possession as tenant of the land.

Petitioner Castillo raised various arguments in his petition for review, asserting that:

The Court of Appeals committed clear and patent error in overruling the trial court’s findings, which were supported by substantial evidence.
The appellate court abused its discretion by designating Ignacio as a tenant based on a judicial admission that he was merely acting as a “magsisiga.”
The issuance of a permanent injunction against Castillo was improper given that Ignacio did not possess the land physically.
The court failed to terminate any relationship between the parties despite evidence of harassment by Ignacio.

The central issue thus set for determination was whether an agricultural tenancy relationship existed between Castillo and Ignacio.

The case pivots on the interpretation of the Agricultural Tenancy Act (R.A. No. 1199), which defines “agricultural tenancy” as physical possession of agricultural land for production through personal cultivation in exchange for sharing of the harvest or payment.
Previous jurisprudence (e.g., Qua v. Court of Appeals and Gagola v. Court of Agrarian Relations) underscores the essentiality of personal cultivation in establishing tenancy.
Facts on record showed that respondent Ignacio’s activities (including hiring non-family members to perform tasks) did not satisfy the requirement of personal cultivation necessary for a tenant-landowner relationship.

Whether the Court of Appeals erred in reversing the trial court’s decision that declared no tenancy relationship between petitioner and respondent.

Did the appellate court commit reversible error by concluding that a tenancy relationship existed despite evidence indicating Ignacio was merely a “magsisiga” and not in actual physical possession?

Whether the permanent injunction against petitioner should have been issued given that respondent was not in actual physical possession of the land.
Whether the evidence, particularly the “Kasunduan” and other documents, sufficiently established the elements required for an agricultural tenancy relationship, including:

Whether the trial court’s award of attorney’s fees was warranted under the circumstances.