G.R. No. 130260 . February 6, 2006.
Hilaria Ramos Vda. de Brigino, petitioner, vs. Dominador Ramos and Filomena Ramos, respondents.

FACTS

Petitioner Hilaria Ramos Vda. de Brigino and her late spouse, Serafin Brigino, were the registered owners of an agricultural land in Bulacan. They filed a petition before the DARAB Provincial Adjudicator to annul two “Kasunduan ng Pamumuwisan” (agricultural leasehold contracts) dated 1973, which were registered by respondents Dominador Ramos (petitioner’s brother) and Filomena Ramos (surviving spouse of another brother). The petitioners alleged that Hilaria’s signatures on the contracts were forged, executed without their knowledge and consent, and thus prayed for the land to be declared untenanted.
The Provincial Adjudicator ruled for the respondents, a decision affirmed by the DARAB Central Office and the Court of Appeals. Despite an NBI report confirming the forgery of Hilaria’s signatures, the adjudicators found that an implied tenancy relationship existed. This conclusion was based on rental receipts issued by Serafin Brigino to the respondents, which evidenced their cultivation of the land and sharing of harvests, thereby estopping the petitioners from denying the tenancy.

ISSUE

Whether or not an implied tenancy relationship existed between the parties, making respondents bona fide tenants entitled to security of tenure.

RULING

Yes, an implied tenancy relationship existed. The Supreme Court denied the petition and affirmed the lower courts’ rulings. The legal logic centers on the establishment of tenancy by implication, notwithstanding the forged written contracts. The essential requisites of a tenancy relationship under Republic Act No. 1199 are: (1) the parties are the landowner and the tenant; (2) the subject is agricultural land; (3) there is consent; (4) the purpose is agricultural production; (5) there is personal cultivation by the tenant; and (6) there is sharing of the harvest or payment of rent.
Here, consent—the element petitioner claimed was absent due to forgery—was validly implied from the acts of the parties. The issuance of rental receipts by petitioner’s spouse over a significant period demonstrated clear acknowledgment of the respondents’ cultivation and sharing of harvests. Tenancy is not solely dependent on a written agreement; it can be created by implication of law based on proven facts and conduct. The factual findings of the DARAB, as affirmed by the Court of Appeals, that the respondents personally cultivated the land and shared the produce, are conclusive. These specialized agencies’ expertise on agrarian matters commands respect and finality. Consequently, all requisites of tenancy were met, vesting respondents with security of tenure.