GR L 56564; (October, 1982) (Digest)
G.R. No. L-56564 October 18, 1982
FILOMENO BARIAS, petitioner, vs. EDUARDA ALCANTARA and COURT OF APPEALS, respondents.
FACTS
Petitioner Filomeno Barias claimed to be a tenant on his father Domingo’s seven-hectare land since 1945, alleging a one-fifth share of harvests. After Domingo’s death in 1977, the land was devised by will to his second wife, respondent Eduarda Alcantara, and their children. The estate was under judicial administration. Filomeno filed an agrarian case against Eduarda, alleging constructive ejection for not receiving his share. Eduarda countered that Filomeno was never a tenant and only entered the land after his father’s death, even committing acts of vandalism, which she reported to the probate court. The trial court and Court of Appeals ruled against Filomeno.
ISSUE
Whether Filomeno Barias was a tenant on the land and was constructively ejected, warranting his reinstatement.
RULING
The Supreme Court affirmed the lower courts’ decisions, ruling Filomeno was not a tenant and was not constructively ejected. The legal logic centered on the failure to prove a tenancy relationship and the impropriety of the suit against Eduarda. Tenancy requires consent of the landowner, personal cultivation, and sharing of harvests. The Court found Filomeno’s claim unsupported. His own witnesses could not confirm his share or tenancy status. Crucially, evidence showed portions of the land were purchased already cultivated and occupied by another caretaker, and Filomeno entered only after Domingo’s death. His theory of constructive ejection by his stepmother was baseless as the land was under custodia legis in the probate proceeding, administered by a court-appointed administrator, not Eduarda. Therefore, Filomeno sued the wrong party; any claim should have been against the judicial administrator. His actions, including a separate suit to set aside the will, indicated a claim of inheritance, not tenancy. The Court found Eduarda’s version, corroborated by evidence of Filomeno’s post-death entry and vandalism, more credible.