G.R. No. 163928 ; January 21, 2015
MANUEL JUSAYAN, ALFREDO JUSAYAN, AND MICHAEL JUSAYAN, Petitioners, vs. JORGE SOMBILLA, Respondent.

FACTS

Wilson Jesena owned four parcels of agricultural land in New Lucena, Iloilo. On June 20, 1970, he designated respondent Jorge Sombilla as his agent to supervise the tilling and farming of his riceland for the 1970-1971 crop year. On August 20, 1971, before the agreement expired, Wilson sold the land to Timoteo Jusayan. Timoteo and Jorge verbally agreed that Jorge would retain possession of the land and deliver 110 cavans of palay annually to Timoteo without accounting for cultivation expenses, provided Jorge paid the irrigation fees. This arrangement continued from 1971 to 1983. In 1975, the land was transferred to Timoteo’s sons, the petitioners. In 1984, Timoteo terminated Jorge’s administration and demanded possession of the land. Due to Jorge’s failure to comply, Timoteo filed a complaint for recovery of possession and accounting in the RTC (CAR Case No. 17117). After Timoteo’s death, the petitioners substituted him. Jorge claimed he was an agricultural lessee with security of tenure. The RTC ruled the relationship was one of agency and ordered Jorge to deliver possession. The CA reversed, declaring the relationship was one of agricultural tenancy, making the case an agrarian dispute under the exclusive jurisdiction of the DAR.

ISSUE

1. Whether the relationship between the parties was one of agency or agricultural leasehold.
2. Whether the RTC, acting as a Court of Agrarian Relations, had jurisdiction over the case.

RULING

The Supreme Court denied the petition and affirmed the CA’s decision.
1. The relationship was one of agricultural leasehold, not agency. The elements of agency, particularly representation, were absent. The verbal agreement left agricultural production to Jorge’s sole discretion, with Timoteo’s interest limited to receiving a fixed annual delivery of 110 cavans regardless of actual produce, contradicting the nature of agency where the agent acts on behalf of the principal. Handwritten receipts indicating delivery of palay as “rental” substantiated a lease relationship. The Court distinguished a civil law lease from an agricultural lease (leasehold tenancy), with the key distinction being the personal cultivation by the lessee. Jorge proved he personally cultivated the land with the aid of his immediate farm household (his daughter cultivated one parcel), fulfilling the elements of agricultural tenancy: the object was agricultural land; the landholding (7.9 hectares) was susceptible to personal cultivation; Jorge personally tilled the land; and there was a fixed consideration (110 cavans of palay annually).
2. Consequently, the dispute was an agrarian dispute falling under the exclusive original jurisdiction of the Department of Agrarian Reform (DAR) pursuant to Section 3(d) of Republic Act No. 6657 (Comprehensive Agrarian Reform Law of 1988). The RTC, therefore, had no jurisdiction over the case. As an agricultural lessee, Jorge enjoyed security of tenure and could only be dispossessed for causes authorized by law.