Facts:

The case involves Lourdes Pena Qua as the petitioner and the Honorable Court of Appeals, along with private respondents Carmen Carillo, Eduardo Carillo, Josephine Carillo, Rebecca Carillo, Maria Cepres, Cecilio Cepres, and Salvador Carillo, Jr. The events leading to this case began on July 17, 1986, when Lourdes Pena Qua filed a complaint for ejectment with damages against the private respondents. She claimed ownership of a residential parcel of land, specifically Lot No. 2099 of the Malinao Cadastre, located in Poblacion, Tinapi, Malinao, Albay, with an area of 346 square meters, registered under TCT T-70368. The petitioner alleged that the private respondents were merely squatters who occupied the land without any rental agreement or payment of realty taxes. In their defense, Carmen Carillo, the surviving spouse of the late Salvador Carillo, contended that the lot was a home lot because she and her husband were tenants of the land, which included two adjoining lots also own...

Facts:

Ownership and Occupation of the Land:
Petitioner Lourdes Pena Qua is the registered owner of Lot No. 2099, a 346-square-meter residential land situated in Poblacion, Tinapi, Malinao, Albay. Private respondents, including Carmen Carillo, occupy and have constructed structures (an auto repair shop and three houses) on this lot without paying rent or realty taxes.

Claims of the Parties:
Petitioner claims that private respondents are squatters who settled on the land by mere tolerance. Private respondents, led by Carmen Carillo, counter that they are agricultural tenants of the land, which they allege is a "farm lot." They argue that their tenancy status was established by petitioner's predecessor-in-interest, Leovigildo Pena, who allowed them to construct the structures and cultivate the land.

Lower Court Proceedings:
The Municipal Circuit Trial Court ruled in favor of the petitioner, ordering the private respondents to vacate the land and pay damages. On appeal, the Regional Trial Court modified the decision, dismissing the case against Carmen Carillo, finding her to be an agricultural tenant entitled to stay on the land.

Issue:

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Ruling:

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Ratio:

1. Essential Requisites of Tenancy Relationship:
   For an agricultural tenancy relationship to exist, the following elements must be present:
   a) The parties are the landowner and the tenant.
   b) The subject is agricultural land.
   c) The purpose is agricultural production.
   d) There is consideration (sharing of harvest).
   e) There is consent by the landowner.
   f) There is personal cultivation by the tenant.

2. Application to the Case:

   • The land in question, Lot No. 2099, is a 346-square-meter residential lot, not agricultural land.
   • Private respondents did not engage in agricultural production on the land. Instead, they operated an auto repair shop and constructed residential structures.
   • There was no evidence of a sharing agreement for agricultural produce.
   • Private respondents' occupation of the land did not involve personal cultivation or agricultural activity.

3. Grave Abuse of Discretion:
   The Court found that the Regional Trial Court and the Court of Appeals erred in disregarding the findings of the Municipal Trial Court and in relying on the preliminary findings of the Department of Agrarian Reform without conducting an independent investigation.

4. Legal Authority:
   The Court cited Republic Act No. 3844 (Code of Agrarian Reforms) and Republic Act No. 1199 (Agricultural Tenancy Act), which grant home lot privileges only to qualified agricultural tenants. Since Carmen Carillo did not meet the qualifications, she was not entitled to such privileges.