GR 108941; (July, 2000) (Digest)
G.R. No. 108941; July 6, 2000
REYNALDO BEJASA AND ERLINDA BEJASA, petitioners, vs. THE HONORABLE COURT OF APPEALS, Special Sixteenth Division, ISABEL CANDELARIA and JAMIE DINGLASAN, respondents.
FACTS
The case involves two parcels of agricultural land owned by respondent Isabel Candelaria. The land was originally leased to Pio Malabanan in 1974. Petitioners Reynaldo and Erlinda Bejasa were hired by Malabanan to plant and clear the land. After Malabanan’s death, Candelaria entered into a new lease with Victoria Dinglasan. On December 30, 1984, the Bejasas entered into a one-year “aryenduhan” or “pakyaw na bunga” agreement with Victoria, paying a fixed sum for the right to harvest the fruits. After this agreement expired in December 1985, the Bejasas remained on the land without paying rent or sharing any harvest with the landowner.
The Bejasas filed an action for confirmation of leasehold tenancy. The Regional Trial Court ruled in their favor, finding a tenancy relationship existed, granting them security of tenure, and ordering payment of damages. The Court of Appeals reversed this decision, holding no tenancy relationship was established and ordering the Bejasas to vacate the land and pay rental arrears.
ISSUE
Whether a tenancy relationship exists between petitioners Bejasa and respondent Candelaria.
RULING
No. The Supreme Court affirmed the decision of the Court of Appeals, ruling that no tenancy relationship was established. The Court emphasized that for a tenancy relationship to exist, all indispensable elements must concur: (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) the tenant personally cultivates the land; and (6) the consideration consists of sharing the harvests.
The Court found the element of sharing the harvests absent. The agreement between the Bejasas and Victoria Dinglasan was a fixed-rent “aryenduhan” where the Bejasas paid a lump sum for the right to harvest, with no provision for sharing the produce with the landowner. This is a lease of the land’s fruits, not an agricultural tenancy. Furthermore, the element of consent from the landowner was lacking. Candelaria never consented to a tenancy relationship with the Bejasas; her consent was only to Malabanan and later to the Dinglasans as her lessees. The Bejasas’ possession was merely by tolerance of these lessees. Their continued occupation after the expiry of the “aryenduhan” constituted unlawful possession, making them liable for rental compensation.