Facts:

The case involves Wenceslao Hernandez as the petitioner and the Intermediate Appellate Court, along with private respondents Salvador P. De Guzman, Jr., Quintin Flores, Juan Garcia, Arsenio Flores, Francisco Flores, Aurelio Leviste, and Simon Leviste as respondents. The events leading to this case began with a dispute over agricultural tenancy rights concerning a 53-hectare coconut plantation located in Barangay Perez, Calauan, Laguna. The land was originally owned by the deceased spouses Salvador and Escolastica Tolentino, who had ten children. In 1957, the property was leased to Wenceslao Hernandez by SALESC, Inc. The private respondents claimed to be bona fide agricultural tenants of Hernandez, asserting their rights to a share of the harvest. The trial court found that the private respondents had been cultivating the land since World War II and had a tenancy relationship with the Tolentinos, evidenced by letters from Escolastica Tolentino. The court determined that the pr...

Facts:

1. Property and Ownership:

   • The case involves a 53-hectare coconut land in Barangay Perez, Calauan, Laguna, formerly owned by spouses Salvador and Escolastica Tolentino.
   • By 1969, the property was owned by SALESC, Inc., with Wenceslao Hernandez leasing it since 1957.

2. Plaintiffs' Claims:

   • Private respondents (plaintiffs) claimed to be bonafide agricultural tenants of the land since World War II.
   • They asserted they built their houses on the land due to the Hukbalahap threat and were entitled to a share of the harvest.
   • Letters from Escolastica Tolentino to Quintin Flores acknowledged their role as "bantay" (watchmen) and their entitlement to a share of the harvest.

3. Defendant's Claims:

   • Wenceslao Hernandez argued that the plaintiffs were not tenants but "bantays" who had been dismissed in 1952 or 1953.
   • He claimed they were hired as wage laborers in 1973 for picking and hauling coconuts and denied any tenancy relationship.

4. Trial Court Findings:

   • The court found the plaintiffs to be genuine agricultural tenants.
   • They had cleaned and cleared the land, improved harvests, and received a share of the produce: 1/6 under Mrs. Tolentino and 1/7 under Hernandez.
   • Evidence, including receipts and safe conduct passes, supported their continuous presence since at least 1953.

5. Harvest Shares:

   • The plaintiffs' 1/7 share of the coconut harvest was deemed insufficient, and they were entitled to 30% retroactive to 1980.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Tenancy Relationship:

   • The plaintiffs' continuous possession, cultivation, and receipt of a share of the harvest established a tenancy relationship.
   • The court emphasized that cultivation includes clearing underbrush, promoting growth, and caring for plants, which the plaintiffs had done.

2. Distinction Between Tenants and Wage Laborers:

   • Share tenants receive a portion of the harvest as remuneration, while wage laborers receive fixed salaries.
   • The plaintiffs’ receipt of a share of the harvest, not wages, confirmed their status as tenants.

3. Substantial Evidence in Agrarian Cases:

   • The trial court’s findings, supported by substantial evidence, are conclusive and cannot be reversed by appellate tribunals.

4. Abolition of Share Tenancy:

   • While Republic Act No. 3844 abolished share tenancy, it did not terminate the rights of share tenants in coconut lands.
   • The eventual goal of land ownership for farmers remains a legislative priority.