G.R. No. 205266, January 15, 2020
SPOUSES LAURETO V. FRANCO AND NELLY DELA CRUZ-FRANCO, LARRY DELA CRUZ FRANCO, AND ROMEO BAYLE, PETITIONERS, VS. SPOUSES MACARIO GALERA, JR. AND TERESITA LEGASPINA, RESPONDENTS.

FACTS

This case involves a dispute over two agricultural lots in Nagalangan, Danglas, Abra: Lot No. 2282 owned by Benita Bayle and Lot No. 2344 owned by Spouses Apolonio and Charing Bayle (parents of petitioner Romeo Bayle). On February 5, 2006, respondent Spouses Macario Galera, Jr. and Teresita Legaspina filed a Complaint for legal redemption against petitioners (the Franco Spouses, their son Larry, and Romeo Bayle) before the Regional Adjudicator. The Galera Spouses alleged they were instituted as tenants of the landholdings in 1990 by the Bayle Spouses and Benita Bayle. Apolonio Bayle also used the lots as collateral for a loan from the Galera Spouses. After the deaths of Benita and Charing Bayle, and later Apolonio, Romeo Bayle agreed to sell the properties to the Galera Spouses for P150,000.00. However, Romeo canceled the sale and instead sold the lots to the Franco Spouses on July 19, 2005, through an Extra-Judicial Adjudication of Real Property with Absolute Sale, where Romeo declared himself the sole heir. The Galera Spouses, claiming to be agricultural tenants, sought to redeem the lots. Petitioners argued the Galera Spouses were mere caretakers with no tenancy relationship and thus no right of redemption. The Regional Adjudicator ruled in favor of the Galera Spouses, finding a tenancy relationship and granting the right of redemption. The Department of Agrarian Reform Adjudication Board (DARAB) reversed, holding the Galera Spouses failed to prove tenancy due to lack of evidence on landowner consent and a sharing arrangement. The Court of Appeals reinstated the Regional Adjudicator’s decision, finding sufficient evidence of an implied tenancy relationship. Petitioners filed this Petition for Review on Certiorari.

ISSUE

1. Whether a factual review of the Court of Appeals Decision is appropriate under Rule 45 of the Rules of Court.
2. Whether the Court of Appeals erred in reversing the DARAB Decision and reinstating the Regional Adjudicator’s Decision finding respondent Spouses Galera to be agricultural tenants entitled to legal redemption.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals Decision.
On the first issue, the Court held that while the question of whether a person is an agricultural tenant is factual and generally beyond the scope of a Rule 45 petition, exceptions apply when factual findings of lower courts are conflicting, as in this case where the Regional Adjudicator and Court of Appeals differed from the DARAB. However, the Court noted that petitioners merely alleged the conflict without substantiating how it warranted a factual review, but proceeded to resolve the substantive issue.
On the second issue, the Court ruled that the Court of Appeals did not err. An express agreement is not necessary to establish agricultural tenancy; it can be implied from the conduct of the parties showing all legal requisites. The elements of agricultural tenancy are: (1) the parties are the landowner and the tenant; (2) the subject is agricultural land; (3) there is consent by the landowner; (4) the tenant’s purpose is agricultural production; (5) there is personal cultivation by the tenant; and (6) there is sharing of harvests. The Court found these elements present. Consent was implied from the landowners’ acceptance of harvest shares from the Galera Spouses since 1990, and their failure to object to the cultivation for over a decade constituted ratification. The sharing arrangement was established through witness testimonies that the Galera Spouses delivered shares to the Bayles. The Court cited Santos v. vda. de Cerdenola, where an implied tenancy was recognized after six years of cultivation with the landowner’s knowledge. Thus, the Galera Spouses, as agricultural tenants, have the right of redemption under Section 12 of Republic Act No. 3844 (Agricultural Land Reform Code).