Title
Ceneze vs. Ramos
Case
G.R. No. 172287
Decision Date
Jan 15, 2010
Petitioner claimed tenancy rights over agricultural land, alleging transfer from his father with respondent's consent. Respondent denied tenancy, asserting abandonment. Courts ruled no tenancy relationship existed, dismissing petitioner's claim due to insufficient evidence.
tenancy relationship
agricultural land
landholding

Case Summary (G.R. No. 172287)

Factual Background

Petitioner claimed that in 1981 his father, Julian Ceneze, Sr. (Julian, Sr.), transferred his tenurial rights over the landholding to petitioner with the consent and approval of respondent. Petitioner alleged that thereafter, until April 12, 1991, he had been in actual and peaceful possession and cultivation of the land as tenant. He asserted that on April 12, 1991 respondent forcibly entered and cultivated the land to dispossess petitioner of his tenant rights.

Respondent denied the existence of any tenancy relationship. She maintained that she never instituted petitioner as a tenant in any of her landholdings. She admitted, however, that Julian, Sr. had been the tenant of the landholding. She narrated that when Julian, Sr. migrated to the United States of America in 1985, she allowed Julian, Sr.’s wife to cultivate the land. She herself migrated in June 1988 and thereafter allegedly allowed Julian, Sr.’s son, Julian Ceneze, Jr. (Julian, Jr.), to cultivate the landholding. She stated that Julian, Jr. also migrated to the United States in 1991 without informing her, after which she took possession, cultivated the land, and appropriated the harvest. On April 8, 1991, respondent reported to Gloria Calpito, Municipal Agrarian Reform Officer (MARO) of Manaoag, Pangasinan, the alleged abandonment of the landholding by Julian, Sr., his wife, and Julian, Jr.

Proceedings Before the Provincial Adjudicator and DARAB

On December 19, 1997, the Provincial Adjudicator rendered a decision in favor of petitioner, declaring him the bona fide tenant-lessee of the subject landholding and ordering respondent to maintain petitioner in peaceful possession and cultivation. In determining that petitioner was a bona fide tenant-lessee, the Provincial Adjudicator relied on three types of evidence: (a) a Certification issued by Perfecto Dacasin, Barangay Agrarian Reform Committee (BARC) Chairman, attesting that petitioner was a bona fide tenant of the landholding and that he was ejected sometime in April 1991; (b) an Affidavit executed by Julian, Sr., stating that with respondent’s consent and approval, he transferred his tenurial rights to petitioner before migrating in 1981; and (c) a Joint Affidavit executed by Epifanio Castillo, Romulo Camesario, and Maximo Caquin, tenants of adjacent landholdings, stating that petitioner had been a tenant since 1988 and that they helped in harvesting palay products and delivering respondent’s share of the harvest.

Respondent elevated the case. On April 21, 2004, the DARAB affirmed the Provincial Adjudicator’s decision.

CA Decision and Resolution

Respondent then sought review before the CA. On December 29, 2005, the CA reversed and set aside the DARAB decision and rendered another decision dismissing petitioner’s complaint before the Provincial Adjudicator. Petitioner moved for reconsideration, but the CA denied it through a Resolution dated April 7, 2006, for lack of merit.

Issues Raised in the Petition

Petitioner filed a petition for review on certiorari, alleging that the CA had decided the case not in accord with existing law and jurisprudence, particularly in holding that petitioner failed to establish the existence of a tenancy relationship with respondent.

Governing Legal Principles on Tenancy

In resolving the petition, the Supreme Court emphasized that tenancy is not purely a factual relationship dependent on what an alleged tenant does upon the land. It is also a legal relationship that cannot be presumed. Consequently, the Court required evidence proving the presence of all indispensable elements of agricultural tenancy, namely: (1) the parties are the landowner and the tenant; (2) the subject is agricultural land; (3) there is consent by the landowner; (4) the purpose is agricultural production; (5) there is personal cultivation; and (6) there is sharing of the harvest. The Court further held that the absence of any one element prevents an occupant or cultivator from being considered a de jure tenant entitled to the legal incidents of tenancy.

The Parties’ Evidence and the Supreme Court’s Assessment

The Supreme Court held that petitioner’s evidence did not satisfy the required quantum of proof. It noted that petitioner relied on a BARC certification, an affidavit executed by Julian, Sr., and a joint affidavit of tenants of adjacent landholdings. The Court ruled first that the BARC certification was not binding on it. It explained that certifications or findings by the Secretary of Agrarian Reform or authorized representatives on the presence or absence of tenancy are preliminary or provisional and do not bind the judiciary.

On the substantive elements of tenancy, the Court found petitioner’s proof inadequate, particularly on the indispensable requirements of landowner consent and sharing of the harvest. While petitioner pointed to Julian, Sr.’s affidavit to establish consent, the Court declined to give it credence because the affidavit was not notarized and was not authenticated. The Court characterized the affidavit as self-serving and unreliable and stated that other corroborative evidence should have been presented to show that respondent consented to and approved the alleged transfer of tenurial rights to petitioner.

As to the joint affidavit of the adjacent tenants, the Court held that it likewise failed to prove tenancy in the required sense. The Court observed that the affiants stated that they “helped hand in hand” in harvesting and threshing palay products and helped petitioner deliver respondent’s share each year. It found the affidavit ambiguously worded, considering that the affiants were also tenant-lessees of respondent and could have been referring to their own harvest. The Court further noted that the affiants’ assertion that petitioner became a tenant in 1988 ran counter to petitioner’s own allegation that he became a tenant in 1981. In any event, the Court reiterated that merely working on a landholding does not create a presumption of agricultural tenancy.

The Court also stressed that to establish sharing of harvests, petitioner needed objective proof such as a receipt or comparable solid evidence. It ruled that petitioner presented no receipt for respondent’s share in the harvest and offered no other concrete evidence showing actual sharing. In the Court’s view, petitioner’s case relied on statements that did not meet the required standard beyond a mere scintilla.

Jurisdictional Consequence

Having concluded that petitioner failed to establish the existence of a tenancy relationship with respondent, the

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