Case Digest (G.R. No. 163680)
Facts:
The case involves Monico San Diego (Petitioner) and Eufrocinio Evangelista (Respondent). Monico San Diego has been recognized as an agricultural tenant on a parcel of land located in Barangay San Vicente, Sta. Maria, Bulacan, covered by Transfer Certificate of Title (TCT) Number 98.728 (M), which belonged to his late landlord, Andres Evangelista. After the death of Andres Evangelista in 1994, Eufrocinio Evangelista, his son, inherited the property, which spans a total of three hectares. This land consists of 21,000 square meters designated for rice cultivation and 11,200 square meters planted with bamboo. On June 6, 1996, San Diego filed a complaint against Eufrocinio Evangelista with the Department of Agrarian Reform Adjudication Board (DARAB) Region III Office in Malolos, Bulacan, seeking maintenance of peaceful possession and damages concerning the bamboo-planted section of the property. He alleged that Eufrocinio, along with unknown associates, forcibly entered the bamboo a
Case Digest (G.R. No. 163680)
Facts:
- Parties and Property
- Petitioner: Monico San Diego, who long served as an agricultural tenant.
- Respondent: Eufrocinio Evangelista, son and heir of the late Andres Evangelista.
- Property Description:
- Located in Barangay San Vicente, Sta. Maria, Bulacan.
- Covered by Transfer Certificate of Title No. 98.728 (M).
- Total land area of three hectares, with 21,000 square meters planted with rice and 11,200 square meters planted with bamboo.
- Allegations and Original Dispute
- Petitioner’s Complaint:
- Filed on June 6, 1996 with the DARAB Region III Office in Malolos, Bulacan.
- Alleged that respondent and his unidentified companions forcibly entered the bambooland portion and cut down bamboo trees.
- Maintained that he planted the bamboo trees and was entitled to share in their yield.
- Claimed that the respondent threatened further dispossession and continued cutting.
- Respondent’s Contentions:
- Argued that petitioner is a tenant only with respect to the riceland portion.
- Asserted that the bambooland portion was never subject to tenancy.
- Claimed that the existing bamboo trees had been present since 1937 and were not planted by petitioner.
- Procedural History and Agency Determinations
- Proceedings before DARAB:
- The DARAB Provincial Adjudicator initially dismissed petitioner’s complaint on October 6, 1997.
- The decision was later reversed by DARAB on February 16, 2000, holding that the leasehold contract covered the entire three-hectare land.
- Court of Appeals Involvement:
- The Court of Appeals reversed the DARAB decision on December 18, 2003.
- Cited evidence and established that only the riceland was subjected to a tenancy relationship.
- Elevation to the Supreme Court:
- Petitioner elevated the case via petition for review on certiorari.
- The main contention on appeal was the interpretation of the Agricultural Leasehold Contract provisions.
- Contract and Evidence
- Key Contractual Provisions:
- The Agricultural Leasehold Contract was executed on September 4, 1984.
- It created an agricultural leasehold relation over a farm lot which is a portion of a three-hectare parcel.
- Specific provision mandating the rental payment of 33 cavans of palay per annum during the wet season.
- Interpretation of the Contract:
- Petitioner argued the contract encompassed the entire 3-hectare property, including the bambooland.
- Respondent highlighted that the contract made no mention of bamboo or the bambooland portion.
- Emphasis was placed on the fact that only the rice area had evidence of personal cultivation and harvest sharing.
- Corroborative Evidence and Testimonies:
- Neighbor affidavits and a Barangay Chairman’s statements indicated continuous administrative control of the bamboo area by Andres Evangelista and later by petitioner as heir.
- Exhibit 6-A and handwritten records (“Listahan ng Ani”) documented rentals paid solely from the yield of the riceland.
- Acts contemporaneous and subsequent to the contracting clearly demonstrated the parties' intention regarding tenancy.
Issues:
- Interpretation of the Agricultural Leasehold Contract
- Does the contract cover the entire three-hectare property, including the bambooland, or is it limited to the riceland portion?
- How should the wording “a farm lot which is a portion of a parcel” be interpreted in view of the contract’s context?
- Existence of a Tenancy Relationship in the Bambooland Portion
- Whether the evidentiary requirements for a tenancy relationship, particularly personal cultivation and harvest sharing (as established in Monsanto v. Zerna), are present with respect to the bamboo area.
- Whether the absence of bamboo yield data and payment records for bamboo undermines the claim of tenancy on the bambooland.
- Role of Subsequent Acts and Customs
- Can the parties’ conduct, such as the consistent payment in palay and historical use of the land, confirm the intention limited solely to the riceland?
- Is the prevailing custom regarding rental shares among landlords and tenants applicable in interpreting the disputed clause?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)