G.R. No. 264280 - Rodeo vs. Heirs of Burgos Malaya

In 1952, Leodegario Musico served as caretaker of a cocoland owned by Domingo Gutierrez in Romblon, Romblon.
Upon Gutierrez's death, his daughter, Araceli Gutierrez-Orola, took over management of the property.
Musico moved to Manila for work, and his daughter Florsita along with her husband Ulderico Rodeo (the Rodeo spouses) continued caring for the land.
On Orola's passing, the property administration passed to Gutierrez's grandson, Burgos Malaya.
After Burgos’s death, his heirs, represented by Reynaldo M. Malaya, executed a Kasunduan with the Rodeo spouses allowing them to reside rent-free on the land while caring for it.

In 2009, Ceasar Saul Malaya, one of Burgos’s children, allegedly ordered the Rodeo spouses to vacate the property.
He also instructed relatives to harvest coconuts without the spouses' consent.
Rodeo spouses filed a complaint before the Office of the Provincial Adjudicator claiming agricultural tenancy and entitlement to security of tenure.

The Office of the Regional Adjudicator dismissed the complaint citing failure to prove elements of tenancy, particularly the shared harvest arrangement.
It noted the complaint was against heirs, not the landowner.
On appeal, the Department of Agrarian Reform Adjudication Board (DARAB) affirmed dismissal, highlighting lack of consent by the landowner and shared harvest elements.
DARAB found cultivation was part of caretaking duties, without tenancy status. Musico himself was not a tenant.
The Court of Appeals likewise affirmed the dismissal, finding no agricultural leasehold relationship and no evidence of sharing harvests or landowner's consent.
The Rodeo spouses’ motions for reconsideration were denied.

The Rodeo spouses filed a Petition for Review on Certiorari claiming an implied tenancy relationship exists under the Kasunduan and that they shared harvests.
Respondents argued that there is no agricultural leasehold relation and the issues were settled by lower tribunals.

Agrarian relations evolved from communal ownership to encomienda and hacienda systems during Spanish period.
Early tenancy laws like Act No. 4054 (Philippine Rice Share Tenancy Act) sought to protect tenant-farmers.
Share tenancy was defined as a partnership dividing profits and losses; leasehold tenancy involves paying rent/fixed price for land use.
Republic Act No. 3844 abolished share tenancy, making leasehold the recognized form.
Laws provide lessees rights such as preemption and redemption. Periodic reforms like RA No. 11953 further aligned agrarian policy to social justice goals.

Whether an agricultural leasehold (tenancy) relationship existed between the Rodeo spouses and the heirs of Burgos Malaya.
Whether the Kasunduan executed between the parties constituted a tenancy agreement with the required elements of consent and sharing of harvest.
Whether the lower courts erred in dismissing the complaint and denying the claim for security of tenure.