G.R. No. 255509 - Rodriguez vs. Commission on Elections

Respondents, Spouses Paterno and Rosario Cruz, are the registered owners of a parcel of agricultural land situated in Barangay Sta. Monica, Hagonoy, Bulacan.
The property covers approximately four hectares and is evidenced by Tax Declaration No. 020-10-022-11-027.

The dispute arose when respondents filed a Complaint for Recovery of Possession with Accounting and Damages on 7 May 2007.
The complaint alleged that:

Petitioner Jesus Velasquez unlawfully entered the property without the knowledge or consent of the respondents.
Petitioner’s father-in-law, Bernabe Navarro, had been installed as tenant until he voluntarily relinquished his tenancy rights on 6 April 1985 via a Sinumpaang Salaysay.
Following Navarro’s surrender, no tenant was installed until petitioner’s subsequent occupation.
From 1985 until the filing of the complaint, petitioner neither paid rent nor compensated the respondents.
In 1995, the respondents leased the property to Godofredo Tosco, but petitioner unjustifiably refused to surrender possession to him.

On 15 April 2008, the Regional Trial Court (RTC) of Malolos City, Branch 79, dismissed the complaint due to a lack of jurisdiction.
Respondents filed a motion for reconsideration, which the RTC denied on 27 June 2008 for violation of the three-day notice rule.
Respondents then elevated the matter by filing a Petition for Certiorari before the Court of Appeals, challenging:

The alleged absence of the essential elements that constitute a tenancy relationship.
The procedural denial regarding the motion for reconsideration.

While the petition was pending, petitioner acquired title to the disputed land under Original Certificate of Title No. EP-992-C.
On 12 August 2009, the Court of Appeals reversed the RTC’s ruling and ordered the RTC to assume jurisdiction over the case.
Petitioner filed a motion for reconsideration asserting:

That his acquisition of an emancipation patent and registration of title confirmed his status as the owner and a supposed tenant-beneficiary.
That the dispute, being agrarian in nature, should be within the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB).

On 24 February 2010, the Court of Appeals denied petitioner’s motion for reconsideration.

The central issue pertains to the existence (or lack thereof) of a tenancy relationship between petitioner and respondents.
Petitioner argued that his longstanding involvement in the cultivation of the land, dating from 1975, and subsequent recognition as a farmer-beneficiary supported his claim of tenancy and succession to Navarro’s rights.
Respondents contended that petitioner’s mere occupancy and work on the land did not establish a tenancy, as the essential elements such as mutual consent and the sharing of harvests were absent.

Section 50 of Republic Act (R.A.) No. 6657 and Rule II, Section 1(1.1) of the DARAB 2003 Rules of Procedure vest the DAR with exclusive original jurisdiction over agrarian disputes, provided a valid tenancy exists.
The determination of a tenancy relationship requires the fulfillment of several indispensable elements:

The relationship must be between a landowner and a tenant or agricultural lessee.
There must be consensual agreement and mutual understanding aimed at agricultural production.
The arrangement must include personal cultivation and sharing of harvest between the parties.

Petitioner’s qualification as the successor tenant under Section 9 of R.A. No. 3844 was also in question because he is only related by affinity, not by consanguinity as enumerated by the law.

Whether the factual allegations, including the non-payment of rentals and unauthorized occupation, sufficiently establish a tenancy relationship between petitioner and respondents.
Whether the absence of clear consent and an arrangement for sharing harvests negates the possibility of an implied tenancy.

Whether petitioner can be deemed the bona fide successor of his father-in-law, Bernabe Navarro, under Section 9 of R.A. No. 3844.
Whether being related by affinity qualifies petitioner to assume the rights of a deceased tenant-beneficiary.

Whether the dispute is agrarian in nature, thus invoking exclusive and primary jurisdiction of the DARAB, or whether it constitutes an ordinary civil action (accion publiciana) for recovery of possession to be heard by the RTC.
Whether the issuance of an emancipation patent and registration of title to petitioner renders the tenancy issue moot or does not affect the determination of jurisdiction.