GR 163680; (January, 2006) (Digest)
G.R. No. 163680 ; January 24, 2006
MONICO SAN DIEGO, Petitioner, vs. EUFROCINIO EVANGELISTA, Respondent.
FACTS
Petitioner Monico San Diego claimed to be an agricultural tenant of a three-hectare property in Bulacan, inherited by respondent Eufrocinio Evangelista. The land consisted of 21,000 square meters of riceland and 11,200 square meters of bambooland. San Diego filed a complaint before the DARAB for maintenance of peaceful possession over the bambooland, alleging that Evangelista and companions forcibly cut bamboo trees he had planted and threatened to dispossess him. Evangelista countered that San Diego was a tenant only on the riceland portion, asserting the bambooland was untenanted and the bamboo existed since 1937, not planted by the petitioner.
The DARAB Provincial Adjudicator initially dismissed the complaint, finding the tenancy contract and rental payments pertained solely to the riceland. The DARAB Central Board reversed, holding the written leasehold contract covered the entire three hectares without excluding the bambooland. The Court of Appeals subsequently reversed the DARAB Central Board, reinstating the Provincial Adjudicator’s dismissal.
ISSUE
Whether an agricultural tenancy relationship existed between the parties over the bambooland portion of the property.
RULING
The Supreme Court denied the petition, affirming the Court of Appeals. The Court held that no tenancy relationship was established over the bambooland. Applying the elements from Monsanto v. Zerna, the contract and the parties’ acts demonstrated the relationship was limited to the riceland. The written Agricultural Leasehold Contract specified rental as 33 cavans of palay annually, calculated as 25% of the average rice harvest from 1970-1972, with no mention of bamboo produce or sharing.
The Court emphasized that contemporaneous and subsequent acts of the parties are paramount in interpreting contracts. The evidence, including handwritten records of annual palay rentals paid by San Diego from 1981 to 1994, consistently showed payments only in palay, not bamboo. Respondent’s evidence that the bambooland was always administered separately by the landowner remained uncontroverted. Therefore, the intent and practice of the parties confined the tenancy to the riceland. The general policy of resolving doubts in favor of tenants does not apply where, as here, the contract and factual circumstances clearly delineate the scope of the tenancy.