Case Digest (G.R. No. 128534) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case revolves around VHJ Construction and Development Corporation, represented by its President, Vicente D. Herce Jr. (hereinafter referred to as "petitioner"), versus the Court of Appeals, Department of Agrarian Reform Adjudication Board, Gelacio Batario, and Martin Batario (hereinafter referred to as "respondents"). The events transpired in Cabuyao, Laguna, Philippines, with the final decision rendered by the Supreme Court on August 13, 2004.
The facts began when the petitioner, as the owner of two adjacent parcels of sugar land covered by Transfer Certificate of Title (TCT) Nos. T-97535 and T-97536, entered into a one-year lease agreement with Sinforoso Entredicho on October 24, 1988, for an annual rental of P12,000. The parties explicitly agreed that no tenancy relationship existed between them. During the lease, Entredicho permitted Gelacio and Martin Batario, the private respondents, to work on the property, from which he received a portion of the
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Case Digest (G.R. No. 128534) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Background
- VHJ Construction and Development Corporation, through its President Vicente D. Herce, Jr., is the petitioner.
- The respondents are the Court of Appeals, the Department of Agrarian Reform Adjudication Board (DARAB), and private respondents Gelacio Batario and Martin Batario.
- The case arose from a petition for review on certiorari under Rule 45 of the Rules of Court challenging prior decisions:
- A Court of Appeals Resolution dated November 27, 1996 dismissing the petitioner’s review for failure to comply with a certification requirement.
- A subsequent Resolution dated March 6, 1997 denying the petitioner’s motion for reconsideration.
- Property and Lease Contract Details
- The petitioner owned two adjacent parcels of sugarland:
- Parcel covered by Transfer Certificate of Title (TCT) No. T-97535 – 30,123 square meters.
- Parcel covered by TCT No. T-97536 – 17,424 square meters, located in Barangays Banay-Banay and Pulo, Cabuyao, Laguna.
- On October 24, 1988, the petitioner entered into a one-year lease with Sinforoso Entredicho for an annual rental of P12,000, paid via an Allied Banking Corporation check.
- The lease agreement explicitly stated that no tenancy relationship existed between the petitioner and Entredicho.
- During the lease, Entredicho allowed Gelacio and Martin Batario (the private respondents) to work on the land, and he received his share of the harvest.
- Extensions of the Lease and Dispute Over Possession
- The original lease was extended on October 27, 1989, and again extended for another year thereafter.
- After receiving rental payments, when the lease expired in 1991, the petitioner demanded that Entredicho vacate the premises.
- Entredicho instructed the private respondents to cease work and vacate, but they instead initiated legal action.
- Filing of the Suit by the Private Respondents
- On October 3, 1991, the private respondents filed a complaint before DARAB in Sta. Cruz, Laguna (DARAB Case No. IV-LA-0137-91).
- They sought a declaration that they were agricultural tenants and pleaded for a preliminary injunction.
- Their complaint alleged that:
- Entredicho had employed them as agricultural share tenants.
- They were qualified beneficiaries under the Comprehensive Agrarian Reform Program (CARP).
- They had been sharing the net produce and were entitled to tenurial security.
- Petitioner’s Response and Counterclaim
- The petitioner filed its answer with a counterclaim, asserting that:
- Entredicho was merely a civil lessee, not an agricultural lessee.
- The private respondents were simply farm laborers, not agricultural tenants.
- An affidavit by Entredicho was submitted, where he admitted employing the private respondents without the petitioner’s knowledge.
- Decisions rendered by the Agrarian Reform Adjudicatory Bodies
- The Provincial Agrarian Reform Adjudicator (PARAD) issued a decision on May 16, 1994, dismissing the complaint for lack of merit:
- Declaring that the private respondents were mere farm workers.
- Stating that the subject land was not covered by the CARP Law.
- The private respondents appealed to the DARAB Central Office, which, on June 28, 1996, reversed PARAD’s decision:
- Declaring the respondents as de jure and bona fide leasehold tenants.
- Relying on Section 6 of Republic Act No. 3844 (the Agricultural Land Reform Code) to establish that the act of allowing cultivation in exchange for a share in the harvest formed an agricultural leasehold relationship.
- Reinstatement of Proceedings Before the Supreme Court
- After the dismissal of its petition by the Court of Appeals, the petitioner filed the instant petition before the Supreme Court.
- The petitioner contested that:
- The CA improperly dismissed its petition for failing to comply with SC Circular No. 28-91.
- The DARAB erred in declaring the private respondents as agricultural tenants.
- A motion for reconsideration was filed, and on October 8, 1997, the Supreme Court granted the motion, reinstating the petition and requiring the private respondents to comment.
Issues:
- The Central Question
- Whether the private respondents are de jure agricultural tenants of the petitioner.
- Ancillary Issues
- Whether the requisite elements of an agricultural tenancy—especially the aspect of shared harvest between the landowner and the alleged tenant—are present.
- Whether a tenancy relationship can be presumed merely on the basis of personal cultivation of the land by the respondents without express consent or a sharing agreement with the petitioner.
- The proper application and limits of Section 6 of RA 3844 in conferring tenancy rights when the landowner’s consent is absent, as in the case of a civil lessee’s unauthorized arrangement.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)