G.R. Nos. L-46281-83 August 19, 1988
COCONUT COOPERATIVE MARKETING ASSOCIATION, INC. (COCOMA), petitioner, vs. COURT OF APPEALS, PEDRO COSICO, HERMOGENES COSICO and LUCAS COSICO, respondents.

FACTS

The case involves a fifteen-hectare coconut land in Laguna owned by the spouses Rulloda. From 1964 to 1971, Rosario Vda. de Fule held possession under a yearly “pakyaw” contract to purchase all produce. She utilized the services of the Cosicos (Pedro, Hermogenes, and Lucas) as caretakers, paying them a 1/7 share of the proceeds from the sale of coconuts from their respective four-hectare assignments. Their duties were limited to checking for theft and clearing grass with bolos; they did not perform cultivation using work animals. Harvesting and hauling were done by laborers separately hired and paid by Fule or her buyer. Fule and a subsequent contractor, Eddie Escudero, were members of petitioner COCOMA, which acted as their agent providing management and marketing services from 1964 to 1975. All cleaning and planting expenses were receipted and paid through COCOMA.
In 1971, after years of receiving wages as hired workers, the Cosicos filed separate agrarian cases claiming to be share tenants. The Court of Agrarian Relations (CAR) declared Pedro and Hermogenes Cosico as lawful tenants of COCOMA, ordering their reinstatement, a 70-30 sharing arrangement, and the payment of their share of past harvests. Lucas Cosico was found not to be a tenant. COCOMA appealed, arguing the Cosicos were mere hired laborers or caretakers, not tenants.

ISSUE

Whether a tenancy relationship existed between COCOMA and the Cosicos.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision upholding the CAR. The legal logic centers on the essential elements of agricultural tenancy under Republic Act No. 1199 , as amended: the parties are the landowner and the tenant; the subject is agricultural land; consent is given by both parties; the purpose is agricultural production; there is personal cultivation by the tenant; and harvest sharing is present. The Court found these elements substantiated. The Cosicos performed necessary agricultural tasks like cleaning, clearing, and planting coconut trees, which constitute personal cultivation. Their compensation, a 1/7 share of the harvest, established a sharing arrangement, not a fixed wage. The fact that other laborers were hired for specific harvesting tasks did not negate the Cosicos’ tenancy status, as personal cultivation does not require the tenant to perform every single farm activity alone.
COCOMA, as the acting agent for the land’s possessors (Fule and Escudero) who were its members, was correctly held liable as the party-in-interest managing the landholding. The findings of fact by the CAR, supported by substantial evidence, are conclusive on appellate courts in agrarian cases. The Supreme Court found no reason to disturb these findings, as the evidence on record adequately supported the conclusion that an agricultural tenancy relationship was created.