G.R. No. 175098 - Crisostomo vs. Victoria

Petitioner Ismael V. Crisostomo alleged that he, together with his deceased brother, was the registered owner of a riceland parcel covered by Transfer Certificate of Title No. T-68421, located in Sta. Barbara, Baliuag, Bulacan.
Respondent Martin P. Victoria, claiming tenancy rights, entered and began cultivating a disputed portion of the said riceland.

On June 21, 1973, Crisostomo and his deceased brother allegedly entered into a lease contract with David Hipolito over a portion of the riceland, which was effective until Hipolito’s death on December 2, 1999.
After Hipolito’s death, Crisostomo expected to reclaim possession of the disputed portion.
However, in January 2000, Victoria entered the disputed portion and started cultivating it without the knowledge or consent of Crisostomo.

Crisostomo sought possession of the disputed portion and filed a Complaint for Ejectment before the Office of the Provincial Agrarian Reform Adjudicator of Bulacan.
Victoria, in his Answer, claimed that he was entitled to tenancy rights, asserting a familial relationship with Hipolito and alleging that during Hipolito’s lifetime he performed all tenancy-related duties (e.g., delivering lease rentals and sharing the harvest), thereby implying consent by Crisostomo to his tenancy.

The Office of the Provincial Agrarian Reform Adjudicator of Bulacan ruled on April 7, 2003, in favor of Crisostomo by ordering Victoria, along with persons claiming through him, to vacate and surrender the possession of the disputed portion.
The Department of Agrarian Reform Adjudication Board (DARRAB) subsequently upheld this ruling in its April 4, 2005 Decision and March 17, 2006 Resolution, denying Victoria’s appeal and motion for reconsideration.
The Court of Appeals reversed the ARAB rulings in its July 31, 2006 Decision by recognizing Victoria as the bona fide tenant of the disputed portion and, in its October 20, 2006 Resolution, denied Crisostomo’s Motion for Reconsideration.
Crisostomo then elevated the case via a Petition for Review on Certiorari under Rule 45, seeking to reverse the CA decisions and reinstate the ARAB decisions.

Whether respondent Martin P. Victoria qualifies as a bona fide tenant of the disputed portion under the Agricultural Land Reform Code (Republic Act No. 3844).
Whether Victoria’s claim to tenancy can be sustained based on the alleged acts and receipts that purportedly indicated Crisostomo’s implied consent.

Whether David Hipolito, as the legal possessor and acknowledged tenant under the civil lease contract, had the authority to designate Victoria as a tenant.
Whether a lessee’s capacity extends to entering into a tenancy relation that confers additional security of tenure to a person other than the one originally contracted with the landowner.

Whether the receipts issued by Crisostomo, which listed both Victoria and Hipolito, sufficiently demonstrate the landowner’s consent to recognizing Victoria as tenant.
Whether such evidence establishes all the fundamental elements required for a valid tenancy relationship.