Facts:

• Lourdes Pena Qua is the petitioner against the Honorable Court of Appeals and private respondents Carmen Carillo, Eduardo Carillo, Josephine Carillo, Rebecca Carillo, Maria Cepres, Cecilio Cepres, and Salvador Carillo, Jr.
• On July 17, 1986, Lourdes filed a complaint for ejectment with damages, claiming ownership of Lot No. 2099 in Poblacion, Tinapi, Malinao, Albay, covering 346 square meters and registered under TCT T-70368.
• The petitioner alleged that the private respondents were squatters without rental agreements or payment of realty taxes.
• Carmen Carillo, the surviving spouse of Salvador Carillo, argued that the lot was a home lot as she and her husband were tenants of the land, which included two adjoining lots owned by the petitioner.
• The Municipal Court ruled in favor of the petitioner, declaring the private respondents as squatters and ordering their eviction.
• The Regional Trial Court modified the judgment, dismissing the case against Carmen Carillo, recognizing her as an agricultural tenant entitled to a home lot.
• The petitioner contested this decision, leading to a petition for certiorari before the Supreme Court.

Issue:

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Ruling:

• The Supreme Court ruled that Carmen Carillo is not entitled to be considered an agricultural tenant and does not have the right to a home lot.
• The Court found that the Court of Appeals committed grave abuse of disc...(Unlock)

Ratio:

• The Supreme Court emphasized that the essential requisites for establishing a tenancy relationship were not met.
• The requisites include:
  1. A landowner and a tenant
  2. Agricultural land
  3. Purpose of agricultural production
  4. Consideration
  5. Consent from the landowner for the tenant to work on the land
  6. Personal cultivation by the tenant
  7. Sharing of harvests
• The land in question, measuring 346 square meters, was primarily used for non-agricultural p...continue reading