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    Bautista Vs Araneta

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    Athena Santos
    Petitioner Bautista claimed to be a lawful tenant of a 3-hectare parcel of land formerly owned by Gregorio Araneta II since 1978. In 1991, armed guards sent by respondent Patricia Araneta, the successor to Gregorio Araneta II, disturbed Bautista's possession of the land and threatened him. The Provincial Adjudicator and Department of Agrarian Reform Adjudication Board ruled in Bautista's favor. However, the Court of Appeals reversed, finding that tenancy requires the consent of the true landholder. The Supreme Court affirmed, holding that tenancy cannot be established through the acts of one without rights to the land, and that certifications of ten

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    Bautista Vs Araneta

    Uploaded by

    Athena Santos
    148 views1 page
    Petitioner Bautista claimed to be a lawful tenant of a 3-hectare parcel of land formerly owned by Gregorio Araneta II since 1978. In 1991, armed guards sent by respondent Patricia Araneta, the successor to Gregorio Araneta II, disturbed Bautista's possession of the land and threatened him. The Provincial Adjudicator and Department of Agrarian Reform Adjudication Board ruled in Bautista's favor. However, the Court of Appeals reversed, finding that tenancy requires the consent of the true landholder. The Supreme Court affirmed, holding that tenancy cannot be established through the acts of one without rights to the land, and that certifications of ten

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    Petitioner Bautista claimed to be a lawful tenant of a 3-hectare parcel of land formerly owned by Gregorio Araneta II since 1978. In 1991, armed guards sent by respondent Patricia Araneta, the successor to Gregorio Araneta II, disturbed Bautista's possession of the land and threatened him. The Provincial Adjudicator and Department of Agrarian Reform Adjudication Board ruled in Bautista's favor. However, the Court of Appeals reversed, finding that tenancy requires the consent of the true landholder. The Supreme Court affirmed, holding that tenancy cannot be established through the acts of one without rights to the land, and that certifications of ten

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    148 views1 page

    Bautista Vs Araneta

    Uploaded by

    Athena Santos
    Petitioner Bautista claimed to be a lawful tenant of a 3-hectare parcel of land formerly owned by Gregorio Araneta II since 1978. In 1991, armed guards sent by respondent Patricia Araneta, the successor to Gregorio Araneta II, disturbed Bautista's possession of the land and threatened him. The Provincial Adjudicator and Department of Agrarian Reform Adjudication Board ruled in Bautista's favor. However, the Court of Appeals reversed, finding that tenancy requires the consent of the true landholder. The Supreme Court affirmed, holding that tenancy cannot be established through the acts of one without rights to the land, and that certifications of ten

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    G. R. No.

    135829 - February 22, 2000


    BAYANI BAUTISTA, Petitioner, v. PATRICIA ARANETA, Respondent.
    FACTS:
    Plaintiff alleged that he is the lawful tenant and actual possessor of THREE (3)
    HECTARES, more or less, parcel of land, formerly owned by Gregorio Araneta II.
    Tenancy relationship between the former owner and plaintiff started way back in
    1978. From then on, plaintiff cultivated and possessed the subject landholding in an
    open, peaceful, continuous and uninterrupted manner.
    Sometime in April 1991, plaintiff's peaceful possession and cultivation was disturbed
    and, even interrupted, when a group of armed security guards, through force and
    intimidation, entered the subject landholding and threatened plaintiff with bodily
    harm. These group of armed security guards, allegedly, were sent by herein
    defendant Patty Araneta, successor of Gregorio Araneta II. They warned plaintiff to
    vacate and to stop cultivating the subject landholding. Plaintiff prayed for a TRO and
    preliminary injunction.
    Defendant denies all the allegations of the plaintiff made in the complaint and stated
    the truth in her affirmative and special defenses.
    Provincial Adjudicator of Bulacan decided in favor of petitioner and held that he is a
    bonafide tenant over the land. Department of Agrarian Reform Adjudication Board 4
    affirmed the decision of the Provincial Adjudicator.
    Court of Appeals reversed the decision of the DARAB. It held that "tenancy is not
    purely a factual relationship dependent on what the alleged tenant does upon the
    land. It is also a legal relationship that can only be created with the consent of the
    true and lawful landholder."
    ISSUE: WON petitioner is a tenant of the subject land.
    HELD:
    No. Tenancy relationship can only be created with the consent of the true and lawful
    landholder who is either the "owner, lessee, usufructuary or legal possessor of the
    land" (sec. 5 [b], Rep. Act No. 1199), and not thru the acts of the supposed
    landholder who has no right to the land subject of the tenancy. . . . . To rule otherwise,
    would be to pave the way for fraudulent collusions among the unscrupulous to the
    prejudice of the true and lawful landholder.
    Lastly, we can not sustain petitioner's argument that he is a tenant by virtue of the
    factual finding of the DARAB. As discussed above, DARAB mainly relied on the
    certifications issued in favor of petitioner in holding that he is a tenant in the
    disputed landholding. In Oarde vs. Court of Appeals,15 we held that certifications
    issued by administrative agencies or officers that a certain person is a tenant are
    merely provisional and not conclusive on courts. This Court is not necessarily bound
    by these findings specially if they are mere conclusions that are not supported by
    substantial evidence.

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