G.R. No. 225322 - People vs. Bermudo y Capistrano

This petition for review on certiorari challenges the decision of the Intermediate Appellate Court which had declared Salvador Baltazar a leasehold tenant with security of tenure over a parcel of land measuring 1,740 square meters.
The dispute originated from a complaint filed by Baltazar with the Court of Agrarian Relations (CAR), Branch VI at Baliuag, Bulacan, where he claimed continuous possession as a share tenant since January 1955 on a landhold of approximately 2 hectares in San Miguel, Bulacan.

Respondent Salvador Baltazar alleged he became a tenant under a "kasunduan" (agreement) executed on January 8, 1979 with Socorro Vda. de Balagtas, the owner of a 2-hectare parcel. He further claimed that:

He erected his house and cultivated the land, dividing the produce in his favor (allegedly at ratios of 70-30 and 50-50).
When Socorro Balagtas died, the share pertaining to the landowner was given to her daughter, Corazon Pengson, yet Baltazar maintained that the old contract continued between him and the daughter.

The petitioners (spouses Bonifacio L. Hilario and Eduarda M. Buencamino Hilario) contended that they acquired the disputed 4,000-square-meter portion from the Philippine National Bank after foreclosure, and their title covers only 1,740 square meters.
Testimonies revealed that:

Corazon Pengson testified that her ownership was limited to Lot 427-B (841 m²) and Lot 427-C (899 m²), and that the classification of the property had always been as a “bakuran” (enclosed lot) with no evidence of extensive agricultural cultivation.
Witnesses confirmed Baltazar’s presence on the land but highlighted ambiguity in his contractual arrangement and his failure to pay rentals.

On November 27, 1981, the CAR ruled that the land was not agricultural but rather a plain bakuran, thus concluding that Baltazar was not a tenant on that land.
The Court of Appeals, on January 30, 1982, remanded the case to the CAR for further proceedings due to insufficient evidence supporting the CAR’s initial findings; eventually, additional evidence was admitted leading to a reaffirmation of the absence of a tenancy relationship.
Ultimately, the CAR rendered a decision:

Declaring that Baltazar was not a tenant on the land and ordering his ejectment.
Dismissing the petitioners’ third-party complaint against the Philippine National Bank for lack of merit.

Salvador Baltazar appealed the CAR decision to the Intermediate Appellate Court (IAC).
The IAC reversed the CAR ruling and declared him a leasehold tenant entitled to security of tenure over the 1,740-square-meter land.
The petitioners filed the present petition for review, raising the following assignments of errors:

The IAC disturbed the findings of fact and decision of the CAR, which were supported by substantial evidence.
The IAC substituted its own findings for those of the CAR.
The IAC erred in not affirming the CAR’s characterization of the lots as residential and in determining that Baltazar was not a rightful tenant.

Whether the findings of the Court of Agrarian Relations (CAR) declaring that Baltazar is not a tenant were supported by substantial evidence.
Whether the Intermediate Appellate Court properly disturbed and substituted the CAR’s findings of fact with its own determinations.
Whether the characterization of the disputed property—namely, as residential rather than agricultural—affects the existence of a tenancy relationship.
Whether the essential requisites for a tenancy relationship (i.e., parties involved, the subject being agricultural land, intention for agricultural production, and the presence of consideration) were met in the alleged “kasunduan.”