GR L 63671; (June, 1988) (Digest)
G.R. No. L-63671, June 28, 1988
ROSALINA MAGNO-ADAMOS, LAURO C. ADAMOS and ANGELA GATMAYTAN, petitioners, vs. HON. AGUSTIN O. BAGASAO, MELY DE JESUS, FRANCISCA DE JESUS and GLEN DE JESUS, respondents.
FACTS
Petitioners filed a complaint for recovery of possession of a parcel of land in Nueva Ecija against respondents. In their answer, respondents claimed to be agricultural tenants, thereby challenging the trial court’s jurisdiction. They presented a 1976 “Kasunduan” (agreement) between petitioner Angela Gatmaytan and Melencio De Jesus, using the term “buwisan,” and a report from an Agrarian Inspector certifying a tenancy relationship. Petitioners rebutted this by presenting a certification from the Regional Director of the Ministry of Agrarian Reform finding no tenancy, and endorsements from the National Planning Commission dated as early as 1952, showing the land had been tentatively approved for conversion into a residential subdivision. The trial court declared a tenancy relationship existed and dismissed the case for lack of jurisdiction, holding the Court of Agrarian Relations was the proper forum.
ISSUE
Whether a tenancy relationship existed between the parties, thereby divesting the trial court of jurisdiction over the recovery of possession case.
RULING
The Supreme Court ruled that no tenancy relationship existed. The legal logic centered on the essential requisites of agricultural tenancy, which include: (1) the parties are landholder and tenant; (2) the subject is agricultural land; (3) there is consent; (4) the purpose is agricultural production; (5) there is personal cultivation; and (6) there is sharing of harvests. The Court emphasized that tenancy is not merely a factual relationship but a legal one, where the intent of the parties and their written agreements are paramount.
Examining the 1976 “Kasunduan,” the Court found it established a civil lease, not agricultural tenancy. The agreement stipulated a fixed consideration of P1,000.00 to be paid before working the land, with provisions for possible increases communicated in advance. Critically, there was no stipulation for sharing the harvests between the parties. The agreement also allowed the landowner to recover possession at any time after harvest. These terms are inconsistent with a tenancy relationship, which inherently involves risk-sharing through harvest division and a more permanent association aimed at agricultural production. The use of the word “buwisan” did not automatically create tenancy, as the substantive provisions of the contract controlled. The evidence of prior subdivision approval further supported the land’s non-agricultural character. Consequently, the trial court erred in dismissing the case. The Supreme Court reversed the trial court’s order and directed respondents to vacate and surrender possession of the land to petitioners.