G.R. No. 153595; November 23, 2007
CORNELIO DE JESUS, ET AL., Petitioners, vs. MOLDEX REALTY, INC., Respondent.

FACTS

Petitioners, claiming to be legitimate tenants of Hacienda Sapang Palay in Bulacan, filed a complaint with the DARAB for Maintenance of Peaceful Possession and Damages against respondent Moldex Realty, Inc. Moldex had acquired the property and proceeded to convert it to residential use. Petitioners alleged security of tenure as actual tillers who had been remitting rentals. Respondent, however, recognized only Damaso Leang and Antonia Linquico as legitimate tenants.
The Provincial Adjudicator dismissed the complaint. The DARAB reversed this decision on appeal, recognizing petitioners’ rights as tenants and ordering Moldex to respect their possession. The Court of Appeals, however, partially reversed the DARAB. It affirmed the tenancy status only for Damaso Leang, Agustin Capa, Antonia Linquico, and Sixto Elfa, but dismissed the complaint as to the other petitioners, including Cornelio de Jesus, Servillano Herrera, and others.

ISSUE

Whether the Court of Appeals erred in finding that no tenancy relationship existed between the landowners and petitioners Cornelio de Jesus, et al.

RULING

The Supreme Court denied the petition and affirmed the CA decision. While the question of tenancy is ordinarily factual, the Court reviewed the evidence due to conflicting findings between the DARAB and the CA. The Court held that a tenancy relationship cannot be presumed and must be established by proof of all its essential elements: (1) the parties are the landowner and the tenant; (2) the subject is agricultural land; (3) there is mutual consent; (4) the purpose is agricultural production; (5) there is personal cultivation by the tenant; and (6) there is sharing of harvests.
Petitioners failed to substantiate their claim. The MARO Certification listed them merely as “non-registered/non-legitimate (but actual tillers),” which is insufficient to confer de jure tenancy status. Mere cultivation does not automatically create a tenancy relationship. Furthermore, certifications from agrarian reform officers are not binding on the courts. Petitioners’ evidence, including receipts of payments and a statement of rentals, was deemed inadequate. The receipts showed only payments received by the landowner’s attorney-in-fact without proving an agreed system of harvest sharing. The absence of clear evidence on mutual consent and sharing of harvests was fatal to their claim. Consequently, they were not entitled to security of tenure under agrarian laws.