G.R. No. 120363 - Cecilleville Realty and Service Corp. vs. Court of Appeals

Petitioner Cecilleville Realty and Service Corporation is the registered owner of a parcel of land in Catmon, Sta. Maria, Bulacan, covered by T.C.T. No. 86.494 (M).
The property is the subject of dispute regarding its occupation and use.

Private respondent Herminigildo Pascual occupies a portion of the land.
Herminigildo’s occupation is tied to his assistance to his mother, Ana Pascual, who is the bona-fide tenant of a home lot on the land.
The underlying tenancy relationship was established long ago – dating back to 1976, when Ana Pascual’s father, Sotero Pascual, became a tenant, a relationship which continued by operation of law upon his death and succession by his wife.

After repeated demands to vacate went unheeded by Herminigildo, petitioner initiated an ejectment suit before the Municipal Trial Court of Sta. Maria, Bulacan.

The Municipal Trial Court found no valid tenancy relationship between petitioner and the private respondent, and accordingly ordered Herminigildo to vacate the property and pay attorney’s fees (P10,000.00) plus a monthly sum (P500.00) from the filing of the complaint.

Herminigildo appealed the Municipal Trial Court’s decision to the Regional Trial Court, which set aside the initial decision and remanded the case to the DARAB for further adjudication, noting the tenant’s right to have the assistance of members of her immediate household in farm operations.

The DARAB’s decision underscored that Ana Pascual was entitled to the protection under the law as a bona-fide tenant, including the right to assistance from her immediate household in cultivating the land.
The Court of Appeals later dismissed petitioner's appeal on the basis that there existed a tenancy relationship between the parties dating back to 1976, and that Herminigildo, though not the tenant, was afforded protection as part of Ana Pascual’s immediate farm household.
Central to the issue was the interpretation of Section 22, paragraph 3, of Republic Act No. 1199, as amended by Republic Act No. 2263, which confers the right to a home lot only to the tenant.
Petitioner contended that, while Herminigildo may assist in cultivation as a member of the tenant’s household, he cannot claim the right to occupy a substantial portion of land for residential purposes nor maintain a separate house.

Private respondent argued that, under Section 22(3) of the relevant Act, he is entitled to have a home lot and to maintain a house based on his status as a member of the immediate farm household assisting his elderly and infirm mother.
Petitioner maintained that such a right is exclusive to the bona-fide tenant, and extending it to household members would misinterpret the statute, effectively undermining the protection of the landholder’s property and the intended agricultural use of the land.

Whether the private respondent, as a member of Ana Pascual’s immediate farm household but not as the actual tenant, is legally entitled to a home lot and the right to maintain his own dwelling within the petitioner's land.
Whether the interpretation of Section 22, paragraph 3, of Republic Act No. 1199 (as amended by RA 2263) should be strictly limited to confer rights solely on the tenant, thereby excluding other household members even if they assist in cultivation.
The broader impact on the agricultural tenancy system – specifically, whether permitting a household member to claim a home lot for residential purposes would contravene the law’s purpose of preserving productive agricultural land and ensuring an equitable division of produce and income.