G.R. No. 113605 November 27, 1998
ROMULO ROVILLOS, petitioner, vs. THE HONORABLE COURT OF APPEALS, FOURTH DIVISION, THE HONORABLE RICARDO T. LINSANGAN, PRESIDING JUDGE IN BRANCH 38 OF THE REGIONAL TRIAL COURT OF NUEVA ECIJA, SAN JOSE CITY, AND PRIVATE RESPONDENT MODESTO OBISPO, respondents.

FACTS

Petitioner Romulo Rovillos’s predecessor began cultivating a portion of private respondent Modesto Obispo’s land in Carrangalan, Nueva Ecija, under a share-crop agreement in 1971. On December 30, 1979, the parties executed a “Kasunduan” stipulating that Rovillos was a contracted farm laborer or helper for two hectares of the four-hectare land. Both parties complied for five years. However, starting January 1984, Rovillos began cultivating the land claiming to be a tenant, excluding Obispo. Rovillos anchored his claim on a Certificate of Land Transfer (CLT) issued on October 6, 1981, under P.D. No. 27. Obispo filed a complaint for Recovery of Possession with Damages. The trial court and the Court of Appeals ruled that Rovillos was a mere farm laborer as per the “Kasunduan,” not a tenant, and noted the subsequent cancellation of his CLT.

ISSUE

Whether a contractual stipulation designating an agricultural worker as a mere farm laborer prevails over the factual circumstances and agrarian laws that may establish a tenancy relationship.

RULING

The Supreme Court REVERSED the decisions of the lower courts. The legal logic is that the existence of a tenancy relationship is a question of fact determined by the concurrence of statutory requisites: the parties are landowner and tenant; the subject is agricultural land; there is consent; the purpose is agricultural production; there is personal cultivation; and there is sharing of harvest. The Court found these elements present, as Rovillos was in actual possession, resided on the land, and devoted it to palay production. Crucially, the “Kasunduan” classifying him as a laborer is a void contract for being contrary to law and public policy. Under P.D. No. 27 and subsequent agrarian laws, share tenants were automatically deemed leasehold tenants, and such a status cannot be negated by a contrary private agreement. The contract’s stipulation violated the mandatory “automatic conversion” provision; thus, compliance with it is immaterial. The CLT’s subsequent cancellation, based on the land area being less than seven hectares, was erroneous as P.D. No. 27 covered tenanted rice and corn lands regardless of size. Therefore, Rovillos is an agricultural lessee entitled to security of tenure.