G.R. No. L-27152 - People vs. Torio

Rafael Gelos, the petitioner, claimed that he was a tenant entitled to the benefits of tenancy laws.
Ernesto Alzona, the private respondent, along with the Court of Appeals, was involved in determining the proper legal relationship between the parties.

The subject property is a 25,000 square meter piece of farmland located in Cabuyao, Laguna, originally owned in equal shares by Ernesto Alzona and his parents.
On July 5, 1970, Gelos entered into a written contract with Alzona’s family, being employed as a laborer on the land at a stipulated wage of P5.00 per day.
After Alzona acquired full ownership via purchase of his parents’ share, he terminated Gelos’ services on September 4, 1973 and demanded that Gelos vacate the property.

Gelos refused to leave and sought intervention by filing with the Court of Agrarian Relations on October 1, 1973 for fixing the agricultural lease rental on the land.
Although Gelos later withdrew this case in favor of a petition before the Ministry of Agrarian Reform—which ultimately granted his petition—the dispute over his status persisted.
Alzona pursued relief by filing a complaint for illegal detainer in the Municipal Court of Cabuyao; however, this action was declared “not proper for trial” by the Ministry of Agrarian Reform.
Alzona also sought declarations of non-tenancy and damages in proceedings before both the Ministry of Labor and the Court of Agrarian Relations, the latter of which initially dismissed his complaint in favor of Gelos as a tenant.
The appellate process saw the trial court decision reversed by the Court of Appeals, which ruled that Gelos was not a tenant, ordered him to surrender the land, and held him liable for attorney’s fees and costs.

The employment contract, written in Tagalog under the title “Kasunduan ng Upahang Araw,” contains explicit stipulations indicating that Gelos was hired as a laborer:

The contract states that Gelos “may ibig na magpaupa sa paggawa” (desires to lease his services) at the daily wage of P5.00 for eight hours of work.
It clearly distinguishes him from being included as a tenant, noting that he is “hindi kasama sa bukid kundi upahan lamang” (not a tenant of the land but only a hired laborer).

Evidence such as the specific tasks set out in the contract and the absence of elements typically associated with tenancy (e.g., sharing of harvest or the payment of a rental) supports the interpretation that the agreement was for labor and not for tenancy.
Testimonies and documentary evidence—including receipts for fertilizer and pesticides and payment of irrigation fees—were presented. However, these were countered by the respondent’s explanations and the observation that such payments were consistent with a provisional leasehold arrangement when the Agrarian Reform Office had provisionally fixed a rental.

Attempts by Gelos to argue that he was deceived into signing the contract were undermined by the testimony of Atty. Santos Pampolina, who clarified that Gelos had read and understood the document before signing.
The case also involves discussions of whether the illegal detainer complaint and the action for declaration of non-tenancy fall within the applicable prescriptive periods under RA 3844 and Article 1144 of the Civil Code.
The factual dispute essentially revolves around whether Gelos is a farm tenant or merely a hired laborer, a distinction that determines the applicability of tenancy laws versus labor or employment laws.

Whether Rafael Gelos qualifies as a tenant under the agricultural tenancy relationship or is merely a hired laborer providing services under a contract of employment.

Whether the stipulations contained in the employment contract (e.g., the daily wage, description of work, and explicit disclaimer of tenancy) override Gelos’ contention of tenancy.

Whether the factual findings by the trial court, initially favoring a tenancy relationship, can be revisited or reversed under Rule 45 of the Rules of Court in this petition for review.

Whether the filing of the complaint for illegal detainer and subsequent actions were proper, and if the applicable prescriptive periods under the law were met or should bar the claim.