G.R. No. 144071 . August 25, 2005.
Spouses Alejandro A. Joson and Lourdes Samson, Petitioners, vs. Reynaldo Mendoza and Agapito Laquindanum, Respondents.

FACTS

Petitioners, the registered owners of a 1.25-hectare riceland in Bulacan, entered into an Agricultural Leasehold Contract with Pastor Mendoza in 1987. In 1994, petitioners filed a complaint before the Provincial Agrarian Reform Adjudicator (PARAD) to recover possession, alleging that Pastor Mendoza had migrated to the United States as a permanent resident, thereby abandoning the landholding. They further asserted that they never consented to respondents Reynaldo Mendoza (Pastor’s son) and Agapito Laquindanum tilling the land.
The PARAD ruled in favor of respondents, ordering petitioners to recognize Reynaldo Mendoza as the new tenant. On appeal, the Department of Agrarian Reform Adjudication Board (DARAB) modified the decision. It found that Pastor Mendoza had indeed abandoned the land and that respondents were not tenants but mere farm workers. However, the DARAB barred petitioners from recovering possession, citing the Comprehensive Agrarian Reform Law (CARL), which it interpreted as securing the respondents in their farming activities. The Court of Appeals affirmed the DARAB decision, adding that petitioners were estopped from denying respondents’ status as they had been accepting lease rentals from Reynaldo Mendoza for years.

ISSUE

Whether the Court of Appeals erred in affirming the DARAB decision which barred the landowners from recovering possession of their landholding despite a finding that the original tenant had abandoned it and that the current tillers were not tenants with the landowners’ consent.

RULING

The Supreme Court reversed the decisions of the Court of Appeals and the DARAB. The legal logic is clear: the existence of a tenancy relationship is indispensable for the application of agrarian laws providing security of tenure. Such a relationship requires, among other elements, the consent of the landowner. The DARAB itself categorically found that Pastor Mendoza abandoned the landholding and that respondents were not tenants but mere farm workers or actual tillers to whom petitioners never gave consent, whether express or implied.
Consequently, no tenancy relationship existed between petitioners and respondents. Without this juridical tie, respondents cannot invoke the protective mantle of agrarian reform laws, such as CARL, to justify their continued possession against the will of the landowners. The Court of Appeals’ finding of estoppel was erroneous, as mere acceptance of rentals, under the circumstances, does not constitute consent to a tenancy relationship where the essential elements are absent. Since no tenancy link was established, petitioners, as owners, have the fundamental right to recover possession of their property. The case was remanded to the DARAB for the proper computation of lease rentals due from respondents for their period of cultivation.