Case Summary (G.R. No. 70736)
Facts of the Case
On January 13, 1981, Salvador Baltazar filed a complaint in the Court of Agrarian Relations claiming to be a share tenant of a 2-hectare land owned by Socorro Vda. de Balagtas since January 1955. Following the death of Balagtas, Baltazar alleged continued possession and cultivation rights, stating he was threatened by the Hilarios, who had acquired part of the land after foreclosure by the Philippine National Bank (PNB). The Hilarios claimed to own the land by virtue of a deed of sale executed with PNB.
Proceedings in Lower Courts
The Court of Agrarian Relations initially ruled against Baltazar, determining that the land in question (4,000 square meters) was not an agricultural landholding. However, the Court of Appeals subsequently remanded the case for further proceedings based on insufficient evidence. Additional evidence was presented, and the CAR ultimately found that no tenancy relationship existed between Baltazar and the former owner, ordering Baltazar's ejectment.
Court of Appeals’ Ruling
In a reversal, the Intermediate Appellate Court declared Baltazar a leasehold tenant entitled to security of tenure, challenging the CAR's findings. The Hilarios contested this ruling, alleging that the Court of Appeals had overstepped by disregarding substantial evidence presented in the lower court and substituting its findings.
Supreme Court’s Analysis
The Supreme Court reaffirmed the CAR's findings, emphasizing that substantial evidence was lacking to support Baltazar's claim as a tenant. The Court noted that Baltazar's assertion of tenancy arose from a contractual agreement (kasunduan) with the previous landowner, but he had relinquished part of the land and did not possess a valid continuing contract with the new owner, Corazon Pengson, after her mother's death.
Legal Principles on Tenancy
The Court reiterated that tenancy is a legal relationship requiring consent from the landholder and necessitating an agricultural purpose for the land. The evidence indicated that the land in question was classified as residential and did not satisfy the criteria for establishing a tenancy relationship. Furthermore, Baltazar’s failure to pay rent or share of the produce to Pengson further undermined his claim.
Nature of the Property
The Supreme Court noted that the disputed property’s location in the poblacion of San Miguel suggested its residential nature, and it hig
...continue readingCase Syllabus (G.R. No. 70736)
Case Summary
- The case involves a petition for review on certiorari filed by Bonifacio L. Hilario and Eduarda M. Buencamino Hilario against the decision of the Intermediate Appellate Court, which declared Salvador Baltazar a leasehold tenant entitled to security of tenure on a parcel of land measuring 1,740 square meters.
- The dispute centers around the claim of Baltazar, who asserted he had been a continuous tenant of a two-hectare parcel of land since January 1955, previously owned by Socorro Vda. de Balagtas, and later by her daughter Corazon Pengzon.
Background of the Case
- On January 13, 1981, Salvador Baltazar filed a verified complaint with the Court of Agrarian Relations in Bulacan, alleging threats from the Hilarios to prevent him from cultivating a portion of the land.
- Baltazar claimed to have a "Kasunduan" (contract) with the former owner, Socorro Vda. de Balagtas, for the two-hectare land, from which he stated he derived produce shared in specified ratios.
- The Hilarios contended they acquired the disputed land from the Philippine National Bank following foreclosure and asserted that the land was not agricultural but residential.
Initial Rulings
- The Court of Agrarian Relations ruled on November 27, 1981, that the land in question was not agricultural and declared Baltazar not a tenant.
- An appeal by Baltazar led to the Intermediate Appel