G.R. No. 219670, June 27, 2018
J.V. LAGON REALTY CORP., REPRESENTED BY NENITA L. LAGON IN HER CAPACITY AS PRESIDENT, PETITIONER, V. HEIRS OF LEOCADIA VDA. DE TERRE, NAMELY: PURIFICACION T. BANSILOY, EMILY T. CAMARAO, AND DOMINADOR A. TERRE, AS REPRESENTED BY DIONISIA T. CORTEZ, RESPONDENTS.

FACTS

The case originated from a complaint for illegal ejectment and damages filed by Leocadia Vda. de Terre against J.V. Lagon Realty Corporation before the DARAB. Leocadia claimed she and her late husband were instituted as share tenants on a 5-hectare agricultural land in 1952. The property was subsequently sold several times, with the spouses allegedly retained as tenants, until J.V. Lagon purchased it in 1988. Leocadia asserted that J.V. Lagon’s subsequent acts, including constructing a scale house and filling portions of the land with earth, constituted illegal ejectment and conversion. She also claimed she was not notified of the sale to J.V. Lagon, thus her right of redemption under agrarian law never commenced.
J.V. Lagon countered that no tenancy relationship existed, presenting evidence that the land was commercial, as it hosted a rural bank, and that no tenant was found cultivating it at the time of purchase. It also raised the affirmative defense of prescription, arguing the complaint was filed more than three years after the cause of action accrued in 1988. The Provincial Adjudicator ruled for J.V. Lagon, but the DARAB and the Court of Appeals reversed, finding Leocadia a tenant with a right to redeem the land.

ISSUE

The core issue is whether a tenancy relationship existed between Leocadia and the landowner, which is a prerequisite for the application of agrarian laws on security of tenure and the right of redemption.

RULING

The Supreme Court REVERSED the Court of Appeals and REINSTATED the PARAD decision dismissing the complaint. The Court held that Leocadia failed to prove the existence of an agricultural tenancy relationship by substantial evidence. The essential elements of tenancy are: (1) the parties are the landowner and the tenant; (2) the subject is agricultural land; (3) there is consent; (4) the purpose is agricultural production; (5) there is personal cultivation by the tenant; and (6) there is sharing of harvests. All these elements must concur.
The Court found the evidence presented—such as a municipal mayor’s certification and affidavits from former owners and officials—insufficient to establish these elements concretely. Certifications on tenancy relations are merely provisional. Crucially, the land was no longer agricultural, as evidenced by the presence of a rural bank and its classification as commercial in the city’s land use plan. The claim of personal cultivation and sharing of harvests was unsubstantiated. Since no tenancy was proven, Leocadia could not invoke the security of tenure provisions of agrarian laws or the right of redemption under Section 12 of R.A. No. 3844. The Court emphasized that the existence of a tenancy relationship is a question of fact and cannot be presumed; it must be established by convincing evidence.