G.R. No. 264280, October 30, 2024
Florsita Rodeo, Marco Rodeo, Deborah Rodeo, Uldarico Rodeo, Jr., and Myralynn R. Hullesca, Petitioners, vs. Heirs of Burgos Malaya, represented by Caesar Saul Malaya, Purificacion Malaya, Gina M. Merano, Cheremie Merano, and Regie Malaya, Respondents.

FACTS

In 1952, Leodegario Musico served as caretaker of a cocoland in Romblon owned by Domingo Gutierrez. After Gutierrez died, his daughter Araceli Gutierrez-Orola managed the property. Musico later moved to Manila to work for Orola’s husband. Musico’s daughter Florsita and her husband Ulderico Rodeo (the Rodeo spouses) continued as caretakers. Upon Orola’s death, Burgos Malaya became the estate administrator. After Burgos’s death, his heirs, represented by Reynaldo M. Malaya, entered into a Kasunduan with the Rodeo spouses, allowing them to reside on the property for free while taking care of it. In 2009, one of Burgos’s children, Caesar Saul Malaya, allegedly ordered the Rodeo spouses to vacate and harvested coconuts without their consent. The Rodeo spouses filed a Complaint before the Office of the Provincial Adjudicator, claiming they were bona fide tenants entitled to security of tenure. The Office of the Regional Adjudicator dismissed the Complaint, finding the Rodeo spouses failed to establish all elements of a tenancy relationship, particularly the sharing of harvests, and noted the case was filed against the heirs, not the landowner. The Department of Agrarian Reform Adjudication Board affirmed, also finding lacking the element of landowner consent, ruling their cultivation was part of caretaker obligations, and that Musico was not a tenant, so they could not succeed as tenants. The Court of Appeals denied the Rodeo spouses’ Petition for Review, affirming the absence of consent and sharing of harvests, and that the Kasunduan did not install them as tenants. The Rodeo spouses filed a Petition before the Supreme Court, arguing an implied tenancy via the Kasunduan and that they cultivated and shared harvests.

ISSUE

Whether the Court of Appeals erred in denying the Petition for Review on the ground that there is no tenancy relationship between the parties.

RULING

The Supreme Court denied the Petition. Cultivating the land of another does not automatically establish an agricultural leasehold relation. The party claiming to be an agricultural lessee must prove the elements are present. The Court reviewed the history of agrarian laws, from the Spanish encomienda and hacienda systems to Acts like the Rice Share Tenancy Act (Act No. 4054) and Republic Act No. 1199, which classified tenancy into leasehold and share tenancy. Republic Act No. 3844 abolished share tenancy and converted it to agricultural leasehold, which provides security of tenure and rights like preemption and redemption. The essential elements of an agricultural leasehold are: (1) the parties are the landowner and the agricultural lessee; (2) the subject is agricultural land; (3) there is consent between the parties; (4) the purpose is agricultural production; (5) the agricultural lessee is personally cultivating the land; and (6) the consideration is a fixed amount in money or produce. The Rodeo spouses failed to prove the elements of consent and sharing of harvests. The Kasunduan only allowed free residence in exchange for caretaking, not cultivation for agricultural production with consent. Their cultivation was incidental to caretaker duties. They also failed to prove sharing of harvests, a crucial element. Since Musico was not a tenant, they could not succeed to tenancy rights. The findings of the lower tribunals, being supported by evidence, are binding. Therefore, no agricultural leasehold relation exists.