G.R. No. 70736 March 16, 1987
Bonifacio L. Hilario and Eduarda M. Buencamino Hilario, petitioners, vs. Honorable Intermediate Appellate Court and Salvador Baltazar, respondents.

FACTS

Salvador Baltazar filed a complaint with the Court of Agrarian Relations (CAR), alleging he had been a share tenant since 1955 on a two-hectare land in San Miguel, Bulacan, previously owned by Socorro Vda. de Balagtas. He claimed that in December 1980, the petitioners, the Hilario spouses, who acquired a portion of the land, threatened to fence off and eject him from an area of 4,000 square meters, violating his security of tenure. Baltazar traced his tenancy rights through a 1979 “Kasunduan” with Balagtas, asserting he continued the arrangement with her daughter, Corazon Pengzon, after Balagtas’s death, sharing produce from plants on the land.
The petitioners, however, acquired a specific parcel of 1,740 square meters (comprising two lots) from the Philippine National Bank after a foreclosure sale. They contended the land was residential, located in the poblacion, and classified as such in tax declarations and the PNB’s appraisal report. Corazon Pengzon testified she owned only these two residential lots, which she described as a “bakuran” (yard) with only bananas and pomelos, and denied receiving any share from Baltazar or having a tenancy relationship with him.

ISSUE

Whether or not a tenancy relationship exists between Salvador Baltazar and the landowners over the disputed landholding, entitling him to security of tenure.

RULING

The Supreme Court ruled that no tenancy relationship existed and reversed the decision of the Intermediate Appellate Court. The legal logic centered on the essential requisites for tenancy under agrarian laws: (1) the parties are landholder and tenant; (2) the subject is agricultural land; (3) the purpose is agricultural production; and (4) there is consideration. The Court found these requisites were not met. Critically, the land was not agricultural. The lots were situated in the poblacion, consistently classified as “residential” in tax declarations and the deed of sale, and described as a yard. The presumption for land inside a poblacion is that it is non-agricultural unless proven otherwise, which Baltazar failed to do. The claim of planting some corn did not convert its character.
Furthermore, the element of consideration was absent. Baltazar’s vague allegation of sharing produce 70-30 or 50-50 in his favor was directly contradicted by Pengzon’s testimony that she never received any share. The Court also noted Baltazar was a full-time government employee and that the area he claimed to cultivate was inconsistently reported. Since all requisites for tenancy must concur, their absence meant Baltazar was not a de jure tenant entitled to security of tenure. The Supreme Court thus affirmed the CAR’s original decision ordering his ejectment.