Case Summary (G.R. No. 128534)
Factual Background
VHJ Construction and Development Corporation owned two adjacent parcels of agricultural land located in Barangays Banay-Banay and Pulo, Cabuyao, Laguna, covered by Transfer Certificate of Title No. T-97535 and TCT No. T-97536. The company entered into a one-year lease agreement with Sinforoso Entredicho for an annual rental of P12,000.00 on October 24, 1988. During this lease period, Entredicho permitted Gelacio and Martin Batario, the private respondents, to work the land and share in the produce. Upon the expiration and subsequent renewal of the lease, VHJ Construction issued demands for Entredicho to vacate the property after the lease ended.
Nature of the Dispute
Following a notice from Entredicho to the Batarios instructing them to cease work and vacate the property post-harvest, the private respondents filed a complaint on October 3, 1991, with the Department of Agrarian Reform Adjudication Board (DARAB) seeking recognition as agricultural tenants of the land. They asserted that they were entitled to security of tenure under the Comprehensive Agrarian Reform Program (CARP). VHJ Construction countered this by claiming that Entredicho was a civil lessee and that the Batarios were merely laborers, not tenants.
Decisions of the Lower Courts
The Provincial Agrarian Reform Adjudicator (PARAD) dismissed the Batarios' complaint, declaring them as farm workers rather than agricultural tenants. This decision was reversed by the DARAB on appeal, which recognized the Batarios as de jure tenants entitled to security of tenure under Republic Act No. 3844. The DARAB reasoned that the Batarios, having cultivated the land and shared the produce with Entredicho, had entered into a leasehold relationship by operation of law.
Issues Raised in the Petition
VHJ Construction subsequently filed a petition for review with the Court of Appeals, asserting that the DARAB erred in its decision. The appellate court dismissed the petition, leading VHJ Construction to escalate the matter to the Supreme Court. The core issue presented for resolution was whether the private respondents qualified as de jure agricultural tenants under existing laws.
Supreme Court's Findings
The Supreme Court evaluated the legal nature of the relationship among VHJ Construction, Entredicho, and the Batarios, reiterating that a tenancy relationship necessitates the mutual consent of the landlord and tenant, along with several essential elements including personal cultivation, agricultural production, and sharing of harvests. The Court held that the Batarios did not establish they were agricultural tenants, as they worked under Entredicho's employment and shared the produce solely with him, not with VHJ Construction.
Legal Conclusions and Rulings
The Court underlined the importance of intent in determining the existence of a tenancy relationship, clarifying that merely worki
...continue readingCase Syllabus (G.R. No. 128534)
Case Background
- The case involves a petition for review on certiorari under Rule 45 of the Rules of Court initiated by VHJ Construction and Development Corporation (petitioner) against the Court of Appeals and the Department of Agrarian Reform Adjudication Board (DARAB).
- The petition stemmed from a resolution dated November 27, 1996, which dismissed the petitioner’s plea due to issues regarding the certification of non-forum shopping, signed by the petitioner’s counsel rather than the petitioner itself.
- A subsequent resolution on March 6, 1997, denied the petitioner’s motion for reconsideration.
Factual Antecedents
- VHJ Construction and Development Corporation owned two adjacent parcels of sugarland, covered by Transfer Certificates of Title (TCT) No. T-97535 and TCT No. T-97536 in Cabuyao, Laguna.
- The petitioner entered into a one-year lease agreement with Sinforoso Entredicho on October 24, 1988, for an annual rental of P12,000, with no tenancy relationship acknowledged by both parties.
- During the lease, Entredicho allowed Gelacio and Martin Batario (private respondents) to work on the land, sharing the produce with Entredicho.
- The lease was extended multiple times until its expiration in 1991, after which the petitioner demanded that Entredicho vacate the premises.
Legal Proceedings Initiated by Respondents
- On October 3, 1991, the private respondents filed a case with the DARAB for the declaration of agricultural tenancy, claiming they were employed as agricultural tenants by Entredicho and were qualified beneficiaries under the Comprehensive Agrarian Reform Pr