G.R. No. L-37736 February 23, 1988
ANTONIO EVANGELISTA Y LISING, petitioner, vs. THE COURT OF APPEALS, LUZ CASTAÑEDA and HEIRS OF BENEDICTO SANCHEZ, respondents.

FACTS

Petitioner Antonio Evangelista filed a complaint for reinstatement and damages in the Court of Agrarian Relations (CAR) against the respondents’ predecessor, Rosario Mendoza Sanchez. He alleged that he had been an agricultural tenant on a 5-hectare land in Bulacan since 1953 and was illegally ejected in April 1965 after informing the landowner of his desire to fix rentals under the Agricultural Land Reform Code ( Republic Act No. 3844 ). The private respondents countered that Evangelista was not a tenant but a civil lessee under written contracts, and that he had voluntarily surrendered the landholding in March 1965.
The defense presented three written contracts: a “Kasulatang Option” (Option Contract) dated June 14, 1956, and two “Kasulatan ng Buwisan” (Lease Contracts) dated February 13, 1960, and February 10, 1963. These contracts stipulated a fixed annual rental of 100 cavans of palay, a three-year lease term with an option to renew, a cash deposit, and provisions that the lessee would leave all improvements on the land without reimbursement. Notably, the contracts contained no stipulation requiring the petitioner to personally cultivate the land.

ISSUE

Whether or not a tenancy relationship, as defined under agrarian laws, existed between the petitioner and the landowner, or whether their relationship was merely one of civil lease.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals, ruling that no tenancy relationship existed. The Court emphasized that a fundamental requisite of agricultural tenancy under the law is that the tenant personally, or with the aid of labor from the immediate farm household, cultivates the land. The evidence, including the testimony of witnesses, established that the petitioner did not personally cultivate the landholding. Instead, he engaged the services of other individuals under a “suyuan” system or other arrangements to perform the plowing, harrowing, and other farm work.
The terms of the written contracts consistently indicated the intent to create a civil lease, not an agricultural leasehold. Key indicators were the fixed annual rental in kind, the definite lease period with an option, the security deposit, and the absence of any covenant for personal cultivation by the lessee. The Court acknowledged the practice of some landowners to disguise tenancy relationships through civil lease contracts to evade agrarian laws. However, in this case, the contracts were found to be bona fide, and the petitioner voluntarily entered into them on three separate occasions over the years. Since the essential element of personal cultivation was absent, no tenancy relationship was created, and the petitioner remained a civil lessee with no protection under the tenancy laws from which his ejectment claim arose.