GR 134735; (December, 2000) (Digest)
G.R. No. 134735 ; December 5, 2000
ANGEL CHICO, petitioner, vs. THE HONORABLE COURT OF APPEALS, CELESTINA P. JOSON, who is acting for herself and in representation of her co-owner namely: BERNARDA, DEMETRIA, CELSA, MAURA, JULIANA, MELENCIO and RAFAEL, all surnamed JOSON, respondents.
FACTS
The Joson family owned agricultural land in Bulacan, divided into two portions separately leased to petitioner Angel Chico and Eugenia Esguerra. The controversy arose when the Josons discovered during a 1988 conference at the Bureau of Agrarian Legal Assistance (BALA) that Chico was physically cultivating the portion previously tilled by Esguerra. The Josons filed a complaint for ejectment and collection of irrigation dues, alleging that Esguerra had conveyed her tenancy rights to Chico without their knowledge or consent. During the case, Chico and the Josons entered into a partial compromise agreement regarding Chico’s lease rental and irrigation fee obligations, which was approved by the DARAB Regional Office. The remaining issue for adjudication was the validity of the alleged transfer of Esguerra’s leasehold rights to Chico and the consequent ejectment complaint.
ISSUE
The core issue is whether a valid tenancy relationship was established between Angel Chico and the Joson family over the landholding previously tenanted by Eugenia Esguerra, thereby precluding Chico’s ejectment.
RULING
The Supreme Court denied the petition, affirming the decisions of the Court of Appeals and the DARAB. The legal logic centers on the essential elements required to establish a de jure agricultural leasehold relationship under agrarian laws. For such a relationship to exist, there must be: (1) consent between the landowner and the tenant; (2) personal cultivation by the tenant; (3) agricultural production as the purpose; and (4) sharing of harvests. The Court emphasized that consent of the landowner is primordial; a tenancy relationship is a legal bond created by mutual will, not by mere factual cultivation.
Both the DARAB and the Court of Appeals found that the Josons were completely unaware of and did not consent to any transfer of leasehold rights from Esguerra to Chico. They vehemently objected upon discovery in 1988. The alleged Certificate of Agricultural Leasehold presented belatedly by Chico was deemed dubious and insufficient to constitute substantial evidence of a valid tenancy over the disputed portion. The Court upheld the finding that the transfer was an “insidious sale” without landlord consent, rendering Chico a mere intruder on that landholding. Consequently, no legal tenancy relationship was created over Esguerra’s former holding, and Chico’s ejectment therefrom was valid. The Court deferred to the factual findings of the lower tribunals, which are conclusive absent grave abuse of discretion.