Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

Title Facts Issue/s Ruling Doctrine

Association of Small GR No. 79777: PD 27, EOs 228 W/N PD 27, PP 131, YES. The To the extent that the measures
Landowners v. DAR Secretary & 229 – Nicolas Manaay and his and EOs 228 and 229 promulgation of PD under challenge merely prescribe
GR Nos. 78742, 79310, 79744, wife own a 9-hectare riceland; retention limits for landowners,
and 79777 while Agustin Hermano, Jr. were validly enacted. 27 by Pres. Marcos in there is an exercise of police
14 July 1989 owned 5. They both have four the exercise of his power for the regulation of
Cruz, J. tenants each on their respective powers under martial private property in accordance
landholdings, who were declared law has already been with the Constitution. But where,
full owners of the said lands by to carry out such regulation, it
EO 228 as qualified farmers
sustained and there becomes necessary to deprive
under PD 27. is no reason to such owners of whatever lands
modify or reverse it they may own in excess of the
The Manaays and Hermano on that issue. As for maximum area allowed, there is
question the constitutionality of definitely a taking under the
PD 27 and EOs 228 and 229.
the power of Pres. power of eminent domain for
Aquino to promulgate which payment of just
GR No. 79310: PP 131, EO 229 PP 131 and EOs 228 compensation is imperative.
– Landowners and sugar planters & 229, the same was
in the Victorias Mill District in authorized by Sec. 6 Title to all
Negros, as well as Planters’ expropriated
Committee, Inc. seek to prohibit of the Transitory
the implementation of PP 131 Provisions of the properties shall be
and EO 229 for being violative 1987 Constitution. transferred to the
of the constitutional provisions Significantly, the State only upon full
on just compensation, due payment of
process, and equal protection.
Congress she is
alleged to have compensation to their
Subsequently, the National W/N the CARP fund undercut has not respective owners.
Federation of Sugarcane Planters provision in PP131 rejected but in fact
(NASP), Manuel Barcelona, and Obiter: One of the basic
Prudencio Serrano filed their
conforms to the substantially affirmed principles of the democratic
own petitions, which also requirements of a the challenged system is that where the rights of
assailed the constitutionality of valid appropriation. measures and has the individual are concerned, the
the abovementioned statutes. specifically provided end does not justify the means.
There is no question that not
that they shall be even the strongest moral
GR No. 79744: EOs 228 & 229
suppletory to RA conviction or the most urgent
– Inocentes Pabico
6657 whenever not public need, subject only to a few
alleges that the then notable exceptions, will excuse
inconsistent with its
DAR Secretary placed the bypassing of an individual’s
provisions.
his landholding under rights. It is no exaggeration to
the coverage of OLT, say that a person invoking a right
NO. PP 131 is not an guaranteed under Art III of the
in violation of due
appropriation Constitution is a majority of one
1
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

process and the measure even if it even as against the rest of the
requirement for just W/N PP 131 and EO does provide for the nation who would deny him that
right.
compensation. 229 should be
creation of the said
Certificates of Land invalidated because fund, for that is not
Transfer were they do not provide its principal purpose.
subsequently issued for retention limits. An appropriation law
to tenants, who then is one the primary
refused to pay lease and specific purpose
rentals to him. He of which is to
then protested the authorize the release
erroneous inclusion of public funds from
of his small the treasury. The
landholding under creation of the fund
OLT and asked for the is only incidental to
recall and W/N the assailed the main objective of
cancellation of the statutes violate the the proclamation,
said CLTs, which was equal protection which is agrarian
denied without clause. reform.
hearing. Although he
filed an MR, EOs 228 NO. This argument is
and 229 were issued, no longer tenable
rendering his MR because RA 6657
moot and academic does provide for such
because the said EOs limits now in Section
directly effected the 6 of the law. As such,
transfer of his land to landowners who were
his farmers-tenants. unable to exercise
their rights of
GR No. 78742: PD retention under PD
316 – The Association 27 shall enjoy the
of Small Landowners retention rights
in the Philippines W/N the assailed granted by RA 6657
invokes the right of statutes are valid under the conditions
retention granted by exercises of police therein prescribed.
PD 27 to owners of power.
rice and corn lands NO. The petitioners
2
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

not exceeding 7 have not shown that

hectares as long as they belong to a
they are cultivating different class and
or intend to cultivate entitled to a different
the same. Their treatment. The
respective lands do argument that not
not exceed the only landowners but
statutory limit but are also owners of other
occupied by tenants properties must be
who are actually made to share the
cultivating such burden of
lands. implementing land
reform must be
Because PD 316 rejected. There is a
provides that no substantial
tenant-farmer in distinction between
agricultural lands these two classes of
primarily devoted to owners that is clearly
rice and corn shall be visible except to
ejected or removed those who will not
from his farmholding see.
until such time as the
respective rights of YES. The subject and
the tenant-farmers purpose of agrarian
and the landowner W/N the content and reform have been
shall have been manner of just laid down by the
determined, they compensation Constitution itself,
petitioned the Court provided for in the which satisfies the
for a writ of CARP Law is violative first requirement of a
mandamus to compel of the Constitution. lawful subject.
the DAR Secretary to However, objection is
issue the IRR, as they raised to the manner
could not eject their of fixing the just
tenants and so are compensation, which
unable to enjoy their it is claimed is
right of retention. entrusted to the
3
Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

administrative
authorities in
violation of judicial
prerogatives.
However, there is no
arbitrariness in the
provision, as the
W/N the CARP and EO determination of just
228 contravene a compensation by the
well-accepted DAR is not by any
principle of eminent means final and
domain by divesting conclusive upon the
the landowner of his landowner or any
property even before other interested
actual payment to party, because the
him in full of just law provides that the
compensation. determination made
by the DAR is only
preliminary unless
accepted by all
parties concerned.
Otherwise, the courts
will still have the
right to review with
finality the said
determination.

NO. Although the

traditional medium
for payment of just
compensation is
money and no other,
what is being dealt
with here is not the
traditional exercise of
the power of eminent
4
Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

domain. This is a
revolutionary kind of
expropriation, which
involves not mere
millions of pesos. The
initially intended
amount of P50B may
not be enough, and is
in fact not even fully
available at this time.
The invalidation of
the said section will
result in the
nullification of the
entire program.

NO. EO 228
categorically stated
that all qualified
farmer-beneficiaries
were deemed full
owners of the land
they acquired under
PD 27, after proof of
full-fledged
membership in the
farmers’ cooperatives
and full payment of
just compensation.
The CARP Law, for its
part, conditions the
transfer of
possession and
ownership of the land
to the government on
receipt by the
5
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

landowner of the
corresponding
payment or the
deposit by the DAR of
the compensation in
cash or LBP bonds
with an accessible
bank. Until then, title
also remains with the
landowner.
Sigre v. CA Matias Yusay owned a parcel of W/N PD 27 sanctions MC 6. YES. It was pursuant to PD 27 The power of subordinate
GR Nos. 109568 and 113454 irrigated rice land in Iloilo, in that MC 6 was issued by the legislation allows administrative
8 August 2002 which Ernesto Sigre was a DAR. The Circular was meant to bodies to implement the broad
Austria-Martinez, J. tenant. Sigre previously had been remedy the situation where the policies laid down in a statute by
paying Yusay a lease rental of 16 tenant-farmer’s lease rentals to “filling in” the details. All that is
cavans per crop, but stopped the landowner were not credited required is that the regulation
paying in 1991-92. Instead, he in his favor against the should be germane to the objects
remitted the payments to the determined purchase price of the and purposes of the law; that the
LBP pursuant to DAR’s land, thus making him a regulation be not in contradiction
Memorandum Circular No. 6 perpetual obligor for said to but in conformity with the
(MC 6), which set the guidelines purchase price. Since the assailed standards prescribed by law.
in the payment of lease Circular essentially sought to
rental/partial payment by farmer- accomplish the noble purpose of
beneficiaries under the land PD 27, it is therefore valid.
transfer program of PD 27.
W/N an irreconcilable conflict NO. PD 816 provides that the
Lilia Gonzales, co-administratrix exists between PD 816 and MC tenant-farmer shall pay lease
of Yusay’s estate, filed a petition 6, such that PD 816 must prevail rentals to the landowner until the
for prohibition and mandamus over MC 6. value of the property has been
with the CA, seeking to prohibit determined or agreed upon by
the LBP from accepting Sigre’s the landowner and the DAR. On
leasehold rentals. According to the other hand, MC 6 mandates
Gonzales, she had no notice that that the tenant-farmer shall pay
DAR had already fixed the value to the LBP the lease rental after
of the land. Her petition also the value of the land has been
assails the validity of MC 6 and determined. Thus, there is no
PD 27. incompatibility between these
two. On the contrary, the two
The CA then declared MC 6 null supplement each other as they set
and void, and directed the LBP to the guidelines for the payments
return to Gonzales the lease of lease rentals on the

6
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

rentals paid by Sigre, and Sigre agricultural property.

to pay the rentals directly to
Gonzales. W/N PD 27 is unconstitutional NO. Jurisprudence has upheld
for setting limitations on the the constitutionality of the said
judicial prerogative of decree. Moreover, the
determining just compensation. determination of just
compensation under PD 27 is not
final or conclusive, because
unless both the landowner and
the tenant-farmer accept the
valuation by DAR, the parties
may bring the dispute to court in
order to determine the
appropriate amount of
compensation.

W/N RA 6657 superseded or NO. According to EO 229, PD

repealed PD 27. 27 as amended shall continue to
operate with respect to rice and
corn lands, covered thereunder.
Whatever provisions of PD 27
that are not inconsistent with RA
6657 shall be suppletory to the
latter, and all rights acquired by
the tenant-farmer under PD 27
are retained even with the
passage of RA 6657.
Office of the President v. CA and Aurora Tinio-Reyes owned 24 W/N Jose’s land should be NO. There is no doubt that the Seizure only takes effect on the
Heirs of Jose Reyes hectares of land in Nueva Ecija, covered by the OLT under RA original landholding of Aurora, payment of just compensation.
GR No. 131216 which she bequeathed to her 9 6657 or PD 27. consisting of 24 hectares of
19 July 2001 children upon her death, one of Riceland tenanted by farmers
Pardo, J. which was Jose. was covered by PD 27. However,
the expropriation of the
When Jose tried to get a TCT landholding did not take place on
over his lot, he was told that he the effectivity of PD 27, as the
first needed a clearance from the seizure only takes effect on the
DAR attesting to the non- payment of just compensation;
inclusion of his land in the OLT. and the DAR had not even
However, the PARO ruled that determined the just
his land was covered under the compensation for the taking of
OLT. the landholding when it decreed
that the land was under the
The DAR then issued 12 TCTs coverage of RA 6657. Moreover,
in his favor after he appealed the when Aurora died and her
7
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

PARO Decision. However, children inherited the land, they

subsequently, the Secretary of only acquired 2.5 hectares each,
the Office of the President which is decidedly within the
affirmed the PARO as Aurora’s retention area of 7 hectares under
will was not registered prior to PD 27, or 5 hectares under RA
PD 27’s effectivity, and thus 6657.
could not bind third persons.
When Jose appealed, the CA
reversed the Secretary’s Order.
Raising of livestock, poultry, and Gavino Corpuz was a farmer- W/N the waiver of rights is YES. The sale or transfer of Voluntary surrender, as a mode of
swine are excluded from the beneficiary under the OLT contrary to agrarian law. rights over a property covered by extinguishment of tenancy
coverage of the Program of the DAR. Pursuant to a Certificate of Land Transfer is relations, does not require court
CARL.«„Ì„.Õ&Ý}Äó== PD 27, he was issued a void except when the alienation approval as long as it is
certificate of land transfer over 2 is made in favor of the convincingly and sufficiently
âÔsÍnyÐå NZ5È ﾧ OE¤ parcels of agricultural land. government or through proved by competent
wÞêîŠ< ﾵ 7+ž3+Ç›'¨s? hereditary succession. This evYXdIut‡¯«“9aô©lùÀÚLPIõ
iä¹uCÆ¡Xü 4A! Corpuz then mortgaged the land ruling is intended to prevent a 8§ÛBBï¯ÍÄë'¯¨ÈÒ†=Äo×` ﾵ ¯
ɾ}t‚Òù"?Ãhíñ“’Üdi3ßßy3¢"ãá| to the Grospes. In their mortgage reversion to the old feudal &ï‘`‚hy3ö¨JZ2ØQZµ‘Ÿ¤
à«&þ£'#>¥íð¬Ì[„²È‚g®ZÍUQÄÝ contract, Corpuz allowed the system in which the landowners £ÉèÞÅu&>i‹4 Á‚± æs´ ÕØ:
ÝÄUWnÃTÁ¶ÊÚ„¼„A’ spouses Grospe to use or reacquire vast tracts of land, thus
ﾧ 9ä$)fJ| cultivate the land during the negating the government’s
ö“4Nð„IŒáòëG4sqˆŒÝ»k ﾧ kŸ duration of the mortgage. program of freeing the tenant
±çi-±Ì”}j𵸽nŠì)À` Þ]” from the bondage of the soil.
ŠK9lid, to the e8tent Corpuz subsequently instituted a
that the aforecited igro=in$ustrial complaint which alleged that the W/N Corpuz had abandoned his NO. Corpuz’ surrender of
activities are made to "e cvereä Grospes had entered the disputed landholding. possession did not amount to an
by the agrcrian reform program land by force and destroyed the abandonment because there was
of the State.PP palay that he had planted on it. an obligation on the part of the
‰«ùÔÆŽ[LN4böï„¥ƒkil.– However, according to the Grospes to return possession of
ﾵ +,Oär¬ò-\¶2êk__x—ðM“8ýñ! Grospes, Corpuz had already the landholding upon full
5èÇ€²Yxš¨UÊ executed a “Waiver of Rights” payment of the loan. There was
≸âUM9´µ5ÝŠ4ÐCeu'\ over the landholding in favor of no clear, absolute, or irrevocable
”Ѥ{ÿXò1)Š•Òµ: ﾵ »síÛXí9 the spouses in consideration of intent to abandon.
P54k.
ﾤ ÌÔÚƒÒC´X?~p
W/N Corpuz had voluntarily YES. Corpuz’ intention to
A ﾵ ÆU ÂáÉ*5Èmé ﾵ ð( fûdaÏ Provincial Agrarian Reform surrendered his landholding. surrender the landholding was
MYZµfÓ#i®ñãÑœV5#Ï›š˜– Adjudicator Ernesto Tabara ruled clear and unequivocal. He signed
ÿjˆóq¢•ËÛQ:T3‰` ž§b=Í that Corpuz abandoned and his concurrence to the Samahang
ﾤ `R/_Dtš+yzÍÊ… surrendered the landholding to Nayon Resolutions. His
oFœ“ú7už=ÂNäF—Öõ[Corpuz the Samahang Nayon of Nueva voluntary surrender to the
v. Grospe Ecija. Said Samahang Nayon Samahang Nayon qualifies as a
even passed Resolution Nos. 16 surrender or transfer to the
YES. As there is no re!son to and 27 recommending the government because such action
include livestock anD poultry reallocation of said lots to the forms part of the mechanism for
8
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

lands in the co~eraoe`of agraòian Grospes, who were the “most the disposition and the
ref/rm, there is no need to call qualified farmers-beneficiaries.” reallocation of farmholdings of
upon them to distribute from 3% The DARAB and the CA both tenant-farmers who refuse to
of their gross sales and 10% of affirmed the Decision. become beneficiaries of PD 27.
their net profits to their workers
as additional compensation.

NO. Substantial distinctions exist

between land directed purely to
cultivation and harvesting of
fruits or crops and land
exclusively used for livestock,
poultry and swine raising that
make real differences:
1. There are no tenants
nor landlords in
livestock and poultry
businesses;
2. Livestock and poultry
do not sprout from
land;
3. Land is not a primary
resource;
4. Livestock and poultry
production are
industrial activities;
5. Livestock and poultry
farmworkers are
covered by minimum
wage law rather than
by tenancy law.
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9
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

gUxo_ké0
w¡‚e7ýà4¬
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‰l¼BöÉR ﾧ OéŠëÑ@
DëêËÍún¸
GR No. 135297
8 June 2000
Panganiban, J.
+G;ÄÅ´>~˜Ä¼#:£qúý†Ø((! PP 1637 set aside several ÓÍ FRòßæÌHIµêúÖë/û¬À•*Í +!+ôgõJê ¢P±Ê ﾧ ?]D]_HNÓ-AèÈ.;Ù*§;
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townsite areas to absorb the Áƒ·íp69ÓŠu–´´ŸIC=ÑL¹8‡Äó!: GÆ-–ÿﾵ ¹¬ò"9ÐU®ﾧ V ”aÀO! D:´"ÛM… -`râLgS~F-D7’TVáñ7
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10
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

ŽqJ+cÕ%<E¨Natalia Realty v. f™ë]³õ‹l7xoWDÑĹ7-

DAR—Õ µ€)K&Þ€¤q8’Øï$- yÞeºÜÉA’0ïyíÛH¨zR‰Ñ”“éX?
µ8ëð†ÆÍ,mtÙÓt' "»õ| SA^EWMJ]Îí›$Ópâ1
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zãˆ\Šýø½Ìb;:;RÉšÕ®"

g‡·øbZY§ƒujpÛ£^´²QvÒ -
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¢Ægí¦†ÔŠKšì ﾵ R¹f3ÝÇ+íÆC{H
֯}4
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h ﾧ )èeûJ¥GcA;-""ëjÆüþã÷³F°
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—Ï…À¹S·"1¯‹
ﾤ J¶W÷ǤDb§«0·}fW÷µEªÅity
are outside the coverage of
CARL.

“Agricultural land” refers to

“land devoted to agricultural
activity, and not classified as
mineral, forest, residential,
commercial, or industrial land.”
R_጖ê
‰ŒïÃÍ<3'6%ÍÇû¨u7iÓž3“àO¿•

1ãUgÚSŽ9ÓÇ×jÈƺš¶É(g¹÷î¶ôá
þ#Œ¬ÿzf•
gÉ&hC€W
GR No. 103302
12 August 1993
Bellosillo, J.
,ËœÉÕ-*òu{vÇ©sœ†QLåJ-
cˊ̺”$ ﾤ O¥ém%Ñ@7—
L¼CˆKYÖžP ﾤ Rœ¾•Vÿ<éerö
11
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

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Morta v. Occidentall¦/’k ’ä! Jaime Morta and Purificacion W/N the cases are properly NO. Since there is a dispute as to For DARAB to have jurisdiction
d<ÕGaNkIRLeÕ65zÄÂwÆsYÈ Padilla filed a suit against Jaime cognizable by the DARAB. who is the rightful owner of the over a case, there must exist a
“æ$|ß:Â12÷ ˆÚBöZ Occidental, Atty. Mariano land, the issue is clearly outside tenancy relationship between the
˜|P¢g¥À‚ÅŠñ›RðAQô¡Q… Baranda, and Daniel Corral, for DARAB’s jurisdiction. Whatever parties. In order for a tenancy
ÏïK¾åo¤õÄH65ó:$7ƒ¦÷7º;Å Ó6- allegedly gathering pili nuts, findings made by the DARAB agreement to take hold over a
óf¯0wcæ4\Ïå"º-Lstõß•W>üê} anahaw leaves, and coconuts regarding the ownership of the dispute, it would be essential to
\Iá from their respective land and land are not conclusive to settle establish all its indispensable
destroying their banana and the matter. At any rate, whoever elements, to wit:
GR No. 123417
pineapple plants. Occidental is declared to be the rightful 1. That the parties are the
10 June 1999
claimed that he was a tenant of owner of the land, the case landowner and the
Pardo, J.
the actual owner of the land, cannot be considered tenancy- tenant or agricultural
Josefina Baraclan, and that related for it still fails to comply lessee;
Morta and Padilla were not with the other requirements. 2. The subject matter of
actually the owners of the land in Assuming arguendo that Josefina the relationship is an
question. is the owner, then the case is not agricultural land;
between the landowner and 3. That there is consent

12
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

The trial court ruled in favor of tenant. If, however, Morta is the between the parties to
Morta and Padilla. Occidental, et landowner, Occidental cannot the relationship;
al. appealed, contending that the claim that there is consent to a 4. That the purpose of the
case was cognizable by the DAR landowner-tenant relationship relationship is to bring
Adjudicatory Board (DARAB). between him and Morta. Thus, about agricultural
Thus, the RTC reversed the for failure to comply with the production;
lower court and ruled in favor of requisites, the issue involved is 5. That there is personal
Occidental, stating that the case not tenancy-related cognizable cultivation on the part
is a tenancy-related problem by the DARAB. of the tenant or
which falls under the exclusive agricultural lessee; and
jurisdiction of DARAB. The CA Dissent: Davide, CJ. 6. That the harvest is
affirmed the RTC. It is a tenancy-related issue shared between the
because whether it is Josefina or landowner and the
Morta who is the owner of the tenant or agricultural
land is no moment. It does not lessee.
affect Occidental’s tenancy.
Tenancy attaches to the land. The Limited jurisdiction of DAR:
cases filed by Morta and Padilla 1. Adjudication of all
were a clever way to defeat the matters involving
agrarian law. While the cases implementation of
were ostensibly for damages, agrarian reform;
they were, at bottom, a fight on 2. Resolution of agrarian
issues incident to or arising from conflicts and land-
an agrarian relationship. tenure related
problems; and
3. Approval and
disapproval of the
conversion,
restructuring, or
readjustment of
agricultural lands into
residential,
commercial, industrial,
and other non-
agricultural uses.
Monsanto v. Zerna Leonarda Monsanto owned a W/N an agrarian dispute existed YES. The resolution of an agrarian
GR No. 142591 parcel of land, wherein Jesus and between the parties. 1. The subject of the dispute is a matter beyond the
7 December 2001 Teresita Zerna were overseers. In dispute between them legal competence of regular
Panganiban, J. 1995, the Zernas harvested was the taking of courts. The DARAB exercises
coconuts from the plantation coconuts from the primary jurisdiction—both
without Monsanto’s consent, and property owned by original and appellate—to
processed them into copra for the Monsanto; determine and adjudicate all
purpose of confirming their 2. The Zernas were the agrarian disputes, cases,
claim that they are tenants of the overseers of the controversies, and matters or
13
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

land. It was alleged that the total property at the time of incidents involving the
amount that they actually made the taking of the implementation of agrarian laws
was P6,262.50; they deposited coconuts, as can be and their implementing rules and
P5,162.50 with the Barangay gleaned from their regulations.
Secretary of the locality, keeping Kasabutan;
the balance of P1,100.00 for their 3. Monsanto allowed the An agrarian dispute refers to any
labor. Zernas to plant controversy relating to tenurial
Monsanto instituted a criminal coconut, coffee, arrangements—whether
case of qualified theft against the jackfruit, and cacao as leasehold, tenancy, stewardship
Zernas, but the Zernas were shown by the or otherwise—over lands
acquitted for lack of criminal Kasabutan; devoted to agriculture, including
intent. The barangay captain of 4. A tenurial arrangement (1) disputes concerning farm
the locality was ordered to return exists among herein workers’ associations; or (2)
to Monsanto the money that the parties as regards the representation of persons in
Zernas deposited. Monsanto filed harvesting of the negotiating, fixing, maintaining,
an MR for the return of the agricultural products, changing, or seeking to arrange
P1,100.00. as shown by the terms or conditions of such
several remittances tenurial arrangement.
The court then ruled that since made by the Zernas to
the harvesting of the coconuts Monsanto, A tenancy relationship may be
and processing of the same into substantiated by established either verbally or in
copra were not with the consent receipts. writing, expressly or impliedly.
of Monsanto, then they could not
be entitled to compensation for W/N the RTC was stripped of its NO. There is no question that the
their labor. criminal jurisdiction when the RTC had criminal jurisdiction to
CA annulled the Order regarding try the Zernas for the crime of
On appeal, the CA ruled that the the remaining P1,100.00. qualified theft. However, the
trial court had no jurisdiction to resolution of the issue of who is
order the Zernas to pay entitled to the P1,100.00 falls
Monsanto the P1,100.00. squarely within the jurisdiction
Because the dispute involved an of the DARAB, as it is an
agricultural tenancy relationship, agrarian dispute.
the matter fell within the primary
and exclusive jurisdiction of the
DARAB. It then annulled the
RTC order requiring the return of
the P1,100.00.
Sanchez v. Marin David Felix owned a fishpond. W/N a fishpond is an agricultural NO. By virtue of Sec. 2, RA Fishponds are no longer
GR No. 171346 Jaime Sanchez was instituted as land. 7881, the operation of fishponds considered agricultural lands.
19 October 2007 a tenant on the said fishpond, is no longer considered an
Chico-Nazario, J. with a 50/50 sharing agreement. agricultural activity, and a parcel
After a few years, Felix sold and of land devoted to fishpond
transferred ownership of the operation is no longer an
subject fishpond to the Marins. agricultural land.
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 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

As new owners of the fishpond,

they entered into a civil law W/N a tenurial arrangement YES. Although the fishpond is
agreement with their mother, exists between Sanchez and not covered by the CARL, it
Zemaida, which was renewable Zenaida Marin. bears emphasis that Sanchez’
yearly. status as a tenant in the subject
fishpond and his right to security
Zenaida then made an of tenure were already
arrangement with Sanchez previously settled. Having been
wherein Sanchez would receive a declared as a tenant with the
regular salary and a 20% share in right to security of tenure as
the net profit of the fishpond. provided by the law enforced at
When her lease agreement with the time of the filing of the
her children expired, Zenaida complaint, Sanchez has acquired
ordered Sanchez to vacate the a vested right over the subject
premises. Sanchez refused, fishpond. Therefore, even if
asserting that he was a tenant of fishponds were later
the fishpond and not a mere excluded/exempted from CARL
contractual worker; hence, he coverage, and despite the fact
had the right to its peaceful that no CLOA has been issued to
possession and security of Sanchez, the same cannot defeat
tenure. He then asked the court the aforesaid vested right already
to declare him as a tenant of the granted and acquired by Sanchez
subject fishpond, which long before the passage of RA
subsequently did. 7881.
W/N the DARAB has
As Sanchez was already declared jurisdiction over the case. YES. The present case was
as an agricultural tenant of the instituted as early as 1991 when
fishpond, he filed a petition to the law applicable was still RA
the Provincial Agrarian Reform 6657, and fishponds and prawn
Adjudicator (PARAD) for the farms were not yet
fixing of leasehold rentals for his exempted/excluded from the
use of the fishpond. However, CARL coverage. At that time,
Zenaida countered this there was an agrarian dispute
application by filing a case with between the parties. Prior to the
the PARAD to eject Sanchez for enactment of RA 7881 in 1995,
failure to pay the rent and for the case was already pending
failure to render an accounting. appeal before the DARAB.
The PARAD consolidated the 2 Hence, the aforesaid
cases and ruled in favor of amendments cannot be made to
Sanchez. apply to divest the DARAB of its
jurisdiction of the case. Once
Zenaida appealed to the jurisdiction is acquired by the
DARAB, which affirmed the court, it remains with it until the
PARAD decision. The CA full termination of the case.
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 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

reversed the ruling, stating that

the DARAB lacked jurisdiction
over the case. It stated that Sec. 2
of RA 7881, which amended Sec.
10 of RA 6657, excluded private
lands actually, directly, and
exclusively used for prawn farms
and fishponds from the coverage
of the CARL, so that the
operation of a fishpond is no
longer considered an agricultural
activity. Since the cases are not
agrarian disputes, then the
DARAB could not have validly
acquired jurisdiction over the
case.
Nuesa v. CA When Verdillo was issued an W/N the DARAB has NO. Verdillo and Rivera had no While it bears emphasizing that
GR No. 132048 “Order of Award” by the DAR jurisdiction over the case. tenurial, leasehold, or any findings of administrative
6 March 2002 Secretary over 2 parcels of land, agrarian relations whatsoever agencies, which have acquired
Quisumbing, J. it had a condition that Verdillo that could have brought this expertise because their
should personally cultivate the controversy between them within jurisdiction is confined to
land, and pay at least the first the ambit of an “agrarian specific matters are accorded not
installment, within a period of 6 dispute.” Consequently, the only respect but even finality by
months. DARAB had no jurisdiction over the courts, care should be taken
the controversy and should not that administrative actions are
21 years later, Verdillo filed an have taken cognizance of not done without due regard to
application with the DAR for the Verdillo’s petition in the first the jurisdictional boundaries set
purchase of the said lots claiming place. by the enabling law for each
that he had complied with the agency.
conditions set forth in the Order W/N the DARAB acted in grave YES. The revocation by the
of Award. Restituto Rivera abuse of discretion. Regional Director of DAR of the The DAR is vested with the
protested this application, earlier Order of Award by the primary jurisdiction to determine
claiming that it was he who had DAR Secretary falls under the and adjudicate agrarian reform
been in possession of the land administrative functions of the matters and shall have the
and had been cultivating the DAR. The DARAB and its exclusive jurisdiction over all
same. He also filed his own provincial adjudicator or board matters involving the
application for the said parcels in of adjudicators acted erroneously implementation of the agrarian
opposition to that of Verdillo. and with grave abuse of reform program. The DARAN
discretion in taking cognizance has primary original and
After the DAR’s investigation of of the case, then overturning the appellate jurisdiction to
the conflicting claims, it found decision of the DAR Regional determine and adjudicate all
that Verdillo violated the terms Director and deciding the case on agrarian disputes, cases,
of the Order of Award, and the merits without giving Rivera controversies, and matters or
cancelled the said Order. Hence, the opportunity to present his incidents involving the
16
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

Verdillo filed with the Provincial case. implementation of the CARP and
Adjudication Board a petition for other agrarian laws and their
the annulment of the said order. IRRs.
Instead of filing an Answer to the
Petition, Rivera filed a Motion to An “agrarian dispute” is defined
Dismiss. However, the DARAB to include “any controversy
Provincial Adjudicator chose to relating to tenurial arrangements,
resolve the case on the merits, whether leasehold, tenancy,
and ruled in favor of Verdillo. stewardship, or otherwise over
The DARAB and the CA lands devoted to agriculture,
affirmed this decision. including disputes concerning
farmworkers’ associations or
representation of persons in
negotiating, fixing, maintaining,
changing or seeking to arrange
terms or conditions of such
tenurial arrangements. It includes
any controversy relating to
compensation of lands acquired
under RA 6657 and other terms
and conditions of transfer and
other agrarian reform
beneficiaries, whether the
disputants stand in the proximate
relation of farm operator and
beneficiary, landowner and
tenant, or lessor and lessee.
Almuete v. Andres Since the National Resettlement W/N the case is an agrarian NO. The action filed by Almuete The jurisdiction of the DARAB
GR No. 122276 and Rehabilitation dispute and, as such, falls under before the trial court was for is limited to cases involving a
20 November 2001 Administration (NARRA) the DARAB’s jurisdiction. recovery of possession and tenancy relationship between the
Ynares-Santiago, J. awarded a parcel of land to reconveyance of title. The issue parties.
Rodrigo Almuete in 1957, he and to be resolved was who between
his family exercised exclusive Almuete and Andres has a better Elements of a tenancy
possession over it, cultivating it right to the subject property relationship:
and planting narra, fruit trees, considering that both of them are 1. The parties are the
rice, corn, and legumes thereon. awardees of the same property. It landowner and the
was thus a controversy relating tenant or agricultural
However, in 1979, an Agrarian to ownership of the farmland, lessee;
Reform Technologist represented which is beyond the ambit of the 2. The subject matter of
that Almuete could not be found phrase “agrarian dispute.” No the relationship is an
and that he had waived all his juridical tie of landowner and agricultural land;
rights as a NARRA settler. It was tenant was alleged between the 3. There is consent
also stated in the report that the parties, let alone that which between the parties to
actual owner of the land was would so characterize the the relationship;
17
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

Marcelo Andres, who was then relationship as an agrarian 4. The purpose of the
allowed to file his homestead dispute. Consequently, the RTC relationship is to bring
application. was competent to try and decide about agricultural
the case. Its decision was, thus, production;
After the issuance of an original valid and can no longer be 5. There is personal
certificate of title in favor of disturbed, after having attained cultivation on the part
Andres pursuant to his finality. Nothing more can be of the tenant or
homestead patent, he and 10 done with the decision except to agricultural lessee;
other armed persons entered the enforce it. 6. The harvest is shared
subject property and took between the landowner
possession of approximately half and the tenant or
of it. agricultural lessee.

Almuete quickly brought the

matter the DAR’s attention, and
learned of the cancellation of his
award and its subsequent titling
in favor of Andres. Almuete then
filed an action for reconveyance
and recovery of possession
against Andres, which was
granted by the court.

Andres then filed a petition for

certiorari with the CA, assailing
the trial court’s jurisdiction over
the nature as well as the subject
matter of the case. He argued
that since the subject property
was agricultural land covered by
a homestead patent, exclusive
jurisdiction was with the
DARAB, and not with the
regular courts. The CA ruled in
Andres’ favor, and declared the
ruling of the RTC as null and
void for lack of jurisdiction.
Chico v. CA Pedro Chico claims to be the W/N the dispute between the NO. The records of the case fail In order for a tenancy relation to
GR No. 122704 lawful owner of a parcel of land, parties is agrarian in nature. to show any juridical tie binding take serious hold over the
5 January 1998 which the Mananghayas were between the parties or their dispute, it would e essential to
Vitug, J. occupying. He averred that he predecessors-in-interest, let alone first establish all its indispensable
needed the lots for his personal that which would so characterize elements. It is not enough that
use but because the the relationship as an agrarian these requisites are alleged; these
Mananghayas refused to vacate, dispute. Worse, the land subject requisites must be shown in order
18
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

he was constrained to initiate the matter of the controversy was not to divest the regular court of its
case. shown to be an agricultural land; jurisdiction in proceedings
to the contrary, the land appears lawfully began before it.
The Mananghayas assert that the to be located within a residential
true owners of the property in area. Compounding the matter,
question, Don Rafael and Doña no receipt, or any other evidence,
Salud Chico, were succeeded was presented by the
upon their death by their son Mananghayas to prove their
Delfin Chico. They also claim claim that the harvest was shared
that they had long been in lawful between the parties.
possession of the subject parcel
of land as tenants of the deceased
spouses and their son to whom
rentals had been paid.

The RTC ruled in favor of Pedro

and ordered the Mananghayas to
surrender its possession. The
Mananghayas then initiated a
petition for certiorari with the
CA to annul the RTC decision for
being void. They contend that
their tenancy relationship with
the original owners was an
agrarian dispute cognizable
exclusively by the DARAB. The
CA set aside the RTC decision on
the ground that the dispute
between the parties was an
agrarian reform matter.
Isidro v. CA Natividad Gutierrez owns a W/N the parties have a tenurial NO. Based on the statutory Tenancy is not a purely factual
GR No. L-105586 parcel of land, over which her arrangement. definitions of a tenant or lessee, relationship dependent on what
15 December 1993 sister Aniceta was an overseer. it is clear that there is no tenancy the alleged tenant does upon the
Padilla, J. Aniceta allowed Remigio Isidro or agricultural/leasehold land. It is also a legal
to occupy the swampy portion of relationship existing between the relationship. The intent of the
the land, so that he would have parties. There was no contract or parties, the understanding when
enough income to meet his agreement entered into by the farmer is installed, and their
family’s needs, with the Remigio with Natividad nor with written agreements, provided
condition that he vacate the the overseer of the property, for these are complied with and are
property upon demand. Remigio Remigio to cultivate the land for not contrary to law, are even
occupied the land without paying a price certain or to share his more important.
any rental and converted the harvests. Remigio failed to
same into a fishpond. substantiate his claim that he was Unless a person establishes his
paying rent for the use of the status as a de jure tenant, he is
19
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

When Natividad demanded land. not entitled to security of tenure

Remigio to return the land, the nor is he covered by the Land
latter refused to vacate, claiming W/N the case falls under the NO. A case involving an Reform Program of the
that he had spent effort and DARAB’s jurisdiction. agricultural land does not government under existing
invested capital in converting the automatically make such case an tenancy laws.
same into a fishpond. Thus, a agrarian dispute upon which the
complaint for unlawful detainer DARAB has jurisdiction. The An agricultural lessee is a person
was filed by Natividad. law provides for conditions or who, by himself and with the aid
However, it was dismissed by the requisites before the possessor of available from within his
trial court, stating that the land is the land can qualify as an immediate farm household,
agricultural and is thus an agricultural lessee or tenant, and cultivates the land belonging to,
agrarian dispute under the the land being agricultural is or possessed by, another with the
original and exclusive only one of them. The law states latter’s consent for the purposes
jurisdiction of the courts of that an agrarian dispute must be a of production, for a price certain
agrarian relations. The RTC controversy relating to a tenurial in money or in produce or both.
affirmed the decision. arrangement over lands devoted An agricultural lessor, on the
to agriculture. In the absence of a other hand, is a natural or
The CA then reversed the lower tenancy relationship, the juridical person who, either as
courts, and ruled that there was complaint for unlawful detainer owner, civil law lessee,
no tenurial arrangement between is properly within the jurisdiction usufructuary, or legal possessor
the parties, and that Remigio of the MTC. lets or grants to another the
only possessed the property by cultivation and use of his land for
mere tolerance. a price certain.
Sintos v. CA From 1963 to 1983, Teofilo W/N the tenants have a right to YES. There existed a landlord Where persons cultivated the
GR No. 96489 Magarin, Aguido Ebasco, disturbance compensation. and tenant relationship between land and did not receive salaries
14 July 1995 Guillermo and Manuel Casinillo, the parties. He allowed them to but a share in the produce or the
Quiason, J. Sergio Corpus, Severino cultivate the land and, in return, cash equivalent thereof, the
Magarin, Rufina Mendoza, received a share of the harvest. relationship created between
Victoria Orilan, and Fausta Being tenants, they are entitled to them and the landowner is one of
Salidaga had been cultivating disturbance compensation. tenancy and not employment.
portions of a parcel of land
owned by Nicolas Sintos. They
agreed to pay him one-fourth of
their harvest as their shares.
Subsequently, Nicolas amended
the sharing agreement by
requiring them to give him 10
sacks of 50 kilos per sack, per
hectare, per harvest. Thereafter,
the said tenants paid him on the
basis of the new sharing scheme.

When the subject parcel of land

was identified by the Ministry of
20
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

Agrarian Reform as covered

under Operation Land Transfer,
Certificates of Land Transfer
were issued to the tenants.

Nicolas then asked for the

exclusion of his landholding
from the land reform program,
contending that the portions
occupied by his tenants were part
of his land development project,
the Sintos Subdivision. After
investigation, the MAR
recommended the cancellation of
the CLTs in favor of the tenants
and instead recommended the
award to them of disturbance
compensation.

Although no agreement was

reached by the parties with
respect to the amount of
disturbance compensation, the
tenants were ejected from their
landholding when Nicolas started
dumping sand and gravel on the
portions they were cultivating.
They then filed a case against
Nicolas for the payment of
disturbance compensation.

The trial court ruled in favor of

the tenants, and ordered Nicolas
to pay them disturbance
compensation. The CA affirmed
the trial court. Nicolas appealed,
contending that the respondents
do not have a right to the
compensation because they were
not his tenants.
Philbancor v. CA Vicente Hizon, Jr. is the owner of W/N the tenants could still NO. Section 12 of RA 3844 The right of tenancy attaches to
GR No. 129572 agricultural lands which were exercise their right of provides that the right of the landholding by operation of
26 June 2000 tenanted by Alfredo Pare, Pablo redemption, five years after the redemption may be exercised law. The leasehold relation is not
Pardo, J. Galang, and Amado Vie. Hizon registration of the certificate of within 2 years from the extinguished by the alienation or
21
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

mortgaged the subject property sale with the Register of Deeds. registration of the sale. The transfer of the legal possession of
to Philbancor without his redemption period had already the landholding.
tenants’ knowledge, and when he expired when the tenants filed
failed to pay his obligations, the complaint for redemption.
Philbancor was able to acquire Nevertheless, the tenants may
the property at a public auction. continue in possession and
enjoyment of the land in question
The tenants allegedly only found as legitimate tenants because the
out about the mortgage seven right of tenancy attaches to the
years after the public auction, landholding by operation of law.
when they were notified by The leasehold relation is not
Philbancor to vacate the lots. extinguished by the alienation or
Thus, they filed a complaint for transfer of the legal possession of
maintenance of possession with the landholding.
redemption and tenancy right of
pre-emption against Philbancor
and Hizon with the Provincial
Agrarian Reform Adjudication
Board (PARAB).

The PARAB ruled in favor of the

tenants and ordered Philbancor to
execute the necessary Deed of
Redemption in favor of the
tenants.
The DARAB and the CA
affirmed the decision.
Heirs of Roman Soriano v. CA A parcel of land originally W/N the ruling in the land NO. What is in issue in the land Security of tenure is a legal
GR No. 128177 owned by Adriano Soriano registration case in favor of the registration case was ownership. concession to agricultural lessees
15 August 2001 passed on to his heirs who leased spouses Abalos becomes res The security of tenure case which they value as life itself and
Ynares-Santiago, J. the same to the spouses de Vera judicata with respect to the before the DARAB involved the deprivation of their landholdings
for 15 years beginning 1967 security of tenure rights of the issue of possession. It is is tantamount to deprivation of
(until 1982). Roman, one heirs of Roman Soriano. important to note that although their only means of livelihood.
Adriano’s children, was to act as the spouses Abalos have been
caretaker of the property during declared titled owners of the The exercise of ownership yields
the period of the lease. However, subject land, the exercise of their to the exercise of the rights of an
in 1968, the de Vera spouses rights of ownership are subject to agricultural tenant (as provided
ousted him from the property and limitations that may be imposed for in The Tenancy Act).
appointed Isidro and Vidal by law. The Tenancy Act
Versoza as his substitutes. provides one such limitation. Obiter:
Because of this, Roman filed a Agricultural lessees are entitled Possession and ownership are
case for reinstatement and to security of tenure and they distinct legal concepts. There is
reliquidation against the de Vera have the right to work on their ownership when a thing
spouses. On appeal to the CA, he respective landholdings once the pertaining to one person is
22
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

won. Prior to the execution of the leasehold relationship is completely subjected to his will
CA’s decision in 1972, the de established. in a manner not prohibited by
Vera spouses and Roman entered law and consistent with the
into a post-decisional agreement W/N the winning party in a land NO. Roman’s status as tenant is rights of others. Ownership
wherein the spouses allowed registration case can effectively yet to be declared by DARAB. confers certain rights to the
Roman to sub-lease the property eject the possessor thereof, The prevailing party in a land owner, among which are the
as an agricultural tenant until the whose security of tenure rights registration case cannot be right to enjoy the thing owned
termination of the lease in 1982. are still pending determination placed in possession of the area and the right to exclude other
The said agreement was before the DARAB. while it is being occupied by persons from possession thereof.
approved by the agrarian court. once claiming to be an On the other hand, possession is
agricultural tenant, pending a defined as the holding of a thing
After executing an extrajudicial declaration that the latter’s or the enjoyment of a right.
settlement among themselves, occupancy was unlawful. This is Literally, to possess means to
Adriano’s heirs divided the because if Roman’s claim of actually and physically occupy a
property into 2 lots. The first was possession as a tenant of the said thing with or without right.
assigned to Lourdes, Candido, property is proven, it will entitle Possession may be had in two
and the heirs of Dionisia; the him and his heirs to protection ways: possession in the concept
other was assigned to Francisca, against dispossession. of owner and possession of a
Librada, Elocadio, and Roman. holder.
In 1971, the first lot was sold by
its owners to the spouses Abalos, A judgment for ownership does
while the ¾ of the second lot was not necessarily include
sold to the same spouses by possession as a necessary
Elocadio, Francisca, and Librada. incident.

In 1976, the spouses Abalos filed

with the RTC of Pangasinan an
application for registration of
title over the lots they bought
from the heirs of Adriano (the
first one and the ¾ pro-indiviso
share of the second lot sold to
them). The application was
granted by the RTC, and
affirmed both by the CA and SC.

In 1983, Roman, along with

Elocadio and Librada, filed a
case against the Abalos spouses
for annulment of document
and/or redemption, ownership,
and damages. It was denied by
the trial court.

23
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

In 1984, or 11 years after the

approval of the post-decisional
agreement between Roman and
the spouses de Vera, the Abalos
spouses filed with the agrarian
court a motion for execution of
the said post-decisional
agreement which allowed Roman
Soriano to sub-lease the property.
The motion prayed that the
spouses Abalos be placed in
possession of the subject
property, jointly with Roman
Soriano, and to levy so much of
Roman’s property to answer for
the use and occupation of Roman
of 6/7 share of the property.
When Roman died in 1985, he
was substituted by his heirs.
It appears that in 1988, the land
registration court’s decision was
partially executed by partitioning
the second lot into two—one part
in favor of Roman and the other
in favor of the spouses Abalos.
Roman’s heirs appealed to the
CA, which affirmed the partition
but reversed the order of the land
registration court directing the
issuance of a writ of possession
because of the pendency of the
case instituted by Roman against
the Abalos spouses.

In 1993, the SC ultimately

dismissed Roman’s case of
annulment of document and/or
redemption, ownership, and
damages against the Abalos
spouses; as well as the motion
for execution instituted by the
Abalos spouses. Roman’s heirs
then filed with the DARAB a
complaint against the Abalos
24
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

spouses for “Security of Tenure

with prayer for Status Quo Order
and Preliminary Injunction.” The
Abalos spouses, on the other
hand, in view of the SC’s
disposition of the case, moved
for the issuance of an alias writ
of execution and/or writ of
possession to place them in
possession of the first and ¾ of
the second lot. The trial court
held this case in abeyance until
after DARAB resolves the
complaint filed by Roman’s
heirs. The Abalos spouses’ MR
was denied by the trial court, and
on appeal, the CA reversed the
RTC, ordering the issuance of the
writ of possession in favor of the
Abalos spouses.
Hernandez v. IAC The spouses Tolentino owned a W/N the watchers could be YES. The watchers have been in Where a person cultivates the
GR No. 74323 parcel of coconut land. They had considered as agricultural continuous, uninterrupted land and does not receive salaries
21 September 1990 persons living on the said land, tenants. physical possession of their but a share in the produce or the
Medialdea, J. who cleaned and cleared certain respective areas in the cash equivalent of his share in
portions of the plantation for the landholding, which they have lump, the relationship is one of
purpose of improving the cleaned and cleared for the tenancy and not employment.
harvest, were identified as purpose of improving the
“bantay” or watchers over the harvests; they have lived in the An important criterion in
property and entitled to 1/6 share landholding and constructed their determining whether the
in the harvest. Their houses were houses thereon; they were paid in relationship is one of share
built in a cluster inside the an amount equivalent to 1/6 of tenancy is cultivation.
property. the harvest during the ownership
of the Tolentino spouses, and The definition of cultivation is
Subsequently, SALES, Inc. was then later, 1/7 during the period not limited merely to the tilling,
able to acquire the land. Its of Wenceslao’s lease. Their plowing or harrowing of the land.
possession was relinquished to status as tenants based on the It includes the promotion of
Wenceslao Hernandez under a foregoing cannot be gainsaid. growth and the care of the plants,
civil law lease. The watchers’ Where they cultivated the land or husbanding the ground to
pay was reduced to 1/7 of the and did not receive salaries but a forward the products of the earth
harvest. However, from 1980 to share in the produce or the cash by general industry.
1983, they were not paid their equivalent of his share in lump,
shares. the relationship is one of tenancy It may be said that the caretaker
and not employment. The fact of an agricultural land can also
SALES, Inc. averred that the that they have huts erected on the be considered the cultivator of
25
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

watchers had been ejected from landholdings shows they are the land.
the land even before it acquired tenants.
the same; thus, they did not have RA 3844 abolished and outlawed
a right to a share of the harvests, share tenancy and put in its stead
since they were not tenants. It the agricultural leasehold system.
also claimed that under the lease RA 6389 subsequently declared
agreement, Hernandez was that share tenancy was contrary
forbidden to take any tenants, to public policy. Although share
and that these watchers were tenancy was statutorily
only subsequently hired as wage abolished, leasehold tenancy for
laborers to do the picking, coconut and sugar lands has not
gathering, and hauling of yet been implemented. The
cocounuts. The court ruled in policy makers of government are
favor of the watchers, and still studying the feasibility of its
declared them as tenants of application and the consequences
SALES, Inc. and Wenceslao of its implementation.
Hernandez. The latter were also Nonetheless, this did not end the
ordered to pay the former their rights of share tenants in these
unpaid shares in the harvest. The types of lands. The eventual goal
CA affirmed. of legislation of having strong
and independent farmers working
on lands which they own
remains.
Essential requisites of When Victor Valencia acquired CaN a contract of civil law ìease ¸¸²ould be most unfair to the The right to hire a tenant is
two parcels of land, he entered psohibit a civil law lessee from hapless and unsuspecting basically a personal right of a
a tenancy into civil law leases with emploùing a tenant on the land landowner who entered into a landowner, except as may be
relationship:Ò&1º Glicerio Henson and Fr. Andres s5bjecô matTmr of th¥Û civil law lease agreement in good provided by law. Inherent in the
¡¼×ìl†¾œòKý¯ôÉUüø Flores. Henson instituted ﾧ ìáÑÜßœ ﾤ :C=z`l>þ»›Á faith only to realize later on that right of landholders to install a
Crescenciano and Marciano Frias VvÂyãªn›;x[O266ys,JM& he can no longer regain tenant is their authority to do so;
µäÝ<Ÿ“/ipKI‡9„•¼ð@ to work on the property; while v«€Î¿™26d3Ž´-³ possession of his property due to otherwise, without such
å\ Fr. Flores appointed the Friases, AŒ–°þ the installation of a tenant by the authority, civil law lessees as
plus some others, as farmhands. %gF¶ñæ>Ú„ÏWz$ civil law lessee. On the other landholders cannot install a
€”Ô™µÆÕ‘,Mõô±·O¨ However, in Fr. Flores’ lease $¼ñÄú<à4ÂÒ¨Q&ë³nt/ÍáìxÖ{‰ hand, under the express tenant on the landholding.
ø'àC¿+o(.÷ôA contract, there was a stipulation  ‘-WÜ›ÚÆʇ ﾵ t\¦Ö•ëú? provision of Art. 1649 of the
that he was prohibited from Civil Code, the lessee cannot Tenancy relationship has been
¡M-;vB°/ì installing a leasehold tenant
$7êwU£î+íÉé ﾵ Ù—}‚2Qß(å'p
assign the lease without the held to be of a personal character.
q0oRó¤²Ó~‚Y
/</ô…JÒê·‰m4A~Ê thereon. No such prohibition ¢)oÞƾ<asäeÁiÏ&zBÏöñW» ] consent of the lessor, unless there
%.¡»KÀàÑ®±ä.¶@Í:Þ existed in Henson’s contract. ‰ß†óý is a stipulation to the contrary. In Deforciants cannot install lawful
Ù0¡`ßQÔ9bENS©¼‘[‡h?mã the case before us, not only is tenants who are entitled to
—£‘261’sÝ€- When Fr. Flores’ lease period there no stipulation to the security of tenure.
²ñÇ>á°¥óÈpòz! expired, Valencia ordered his contrary; the lessee is expressly
farmhands to vacate the lot. The prohibited from subleasing or A contract of civil law lease can
Äš¡Ï2Ö±ÆéÆ,Rp¸¼rç farmhands refused to do so, and encumbering the land, which prohibit a civil law lessee from
O-=2 ﾤ kÒ1R3¡ìû26ÕÈ actually even secured CLTs over includes installing a leasehold employing a tenant on the land
26
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

ºM¡î€Z ﾤ Py,01SN^p9" the land in their names. Catalino tenant thereon since the right to subject matter of the lease
Mantac, one of the farmhands, do so is an attribute of agreement.
xŽC¶a ¢×ﾧ‡VBÇ^ûí subsequently entered into a ownership.
Æe¶0R‚À©<ßqb«ƒr.ä leasehold contract undertaking to Essential requisites of a tenancy
have a profit-sharing agreement relationship:
U(dý+Bx…ò†Ñ with Valencia. (14) The parties are the
‰¼Œ]â—„¤Aw… landowner and the
After 12 years, DAR investigated tenant;
ŸˆH3»Ò׆•- the matter and found that the (15) The subject is
•„A°g'`~:«>'ür!qÏv!2¦ right of the farmhands to the land agricultural land;
.ðøW¶Éi´;Ýþ4bí+ ceased upon the termination of (16) There is consent;
the lease contracts, except as (17) The purpose is
regards to Mantac, with whom agricultural production;
_³³¨Ñ¸»;•GíÓˆ³A~ Valencia entered into a tenancy (18) There is personal
agreement. As such, it was cultivation; and
ÈÞ›Uz¬ÕÚœ“9‘šA¬k:
recommended that the CLTs (19) There is sharing of
!t9àUÒJ5Uj€- given to the other farmhands be harvests between the
.*¬Œ@žláýJ¬ÙÑnà<› cancelled. However, the parties.
Regional Office disregarded the
Õâ2727`a investigation report and ruled An allegation that an agricultural
%§žàá6d>h÷iyþŸ¾Å that the farmhands had a right to tenant tilled the land in question
continue on the land until does not make the case an
ç6¢}ï1M¯¦æž– otherwise ordered by the court. agrarian dispute. Claims that one
†j1åiÏ’Ý#ô oZ| On appeal to the Office of the is a tenant do not automatically
®Š«~Fö·Ñê«î_7ìª>™ President, then Exec. Sec. give rise to security of tenure.
Teofisto Guingona upheld the The elements of tenancy must
kCðÊ?ﾤ\Îõtôê ruling of the DAR, with the first be proved in order to entitle
¢»rb¥ƒ‹BÅÞ4§(µõ(a{» modification that the area the claimant to security of tenure.
acquired by Valencia as
- homestead be excluded from the The principal factor in
Éœu¼(”žËñHòÙ¿a¼Å coverage of PD 27. determining whether a tenancy
relationship exists is intent.
ö Valencia then appealed to the CA Tenancy is not a purely factual
contending that the Exec. Sec. relationship dependent on what
ÓØã(mÞÖ’;U1ŸœÃŽ{ erred in recognizing the the alleged tenant does upon the
farmhands as tenants, and land. It is also a legal
p’.]²Üéb²ê´Ö— disallowing him and his 7 relationship.
eø9U©™> compulsory heirs
frmm$exercising their right of The security of tenure guaranteed
%ËîñˆN@}03k³îåtŒ retention under RA 6657. by our tenancy laws may be
·… However, the CA"dismissed thd invoked only by tenants de jure,
z©ä"cTš7(¯§õßä>Ä case. not by those who are not true and
lawful tenants.
¢”ýF®îæ‡E¶÷ôë×4
27
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

‰Æ/sBWž±ÀÁ ﾤ¸ê·I’ The act of subletting to third

persons extinguishes the
À™©ÎÅÐ7CÉó¡ã úµ agricultural leasehold relations,
%àE»+yo$¿ôt,ﾵ¡}z´! as this constitutes an
abandonment of the landholding
õ07:øÊW—êÅ due to absence of personal
ﾧ ä{>oÐ4wò²MÓ¥Èù cultivation.

§|þ@ Obiter:
‰xÞšï”:“SË‘^‡³Ò<ëþ Social justice is for the
deserving, whether he be a
è¡õuþ44ÚÓ£ÂaÐþÄú millionaire in his mansion or a
Á,Sm¨ypðDN'wI|”`R8¡ pauper in his hovel. It is never
ì÷OÒ›î@äêÓHNW6m* juÄ»CtÛ*~·¸¸>@V«XvºVEŸÕ/Ò
0Òqì8ôôl—ôcW°RÇŽ›xÚ1+
ysoj Dp*puËB±/‚¼- U¥DïD@-
Ä‚XŽcðøÁ~«0VˆÆÚ8 ïÝSîugñ"çB<§FoþZµ2¦Z=
%dk§räãe¬×b?÷5si ﾧ wÀÂ#p¦›
UÁ!s¯??ëF.t¸< † æ¢e¢Œí9î?œ¢2¨ ¢
·¯¥˜¦¿]â— ﾤ ¹RR Em‡Í5Š¾!¥€DkvÕ(·Kþ
‚±Ab2 6±hìdE –
_ÅË5åž•ÚÉ‚„ð½ÀCDmE«ö{C€
8ÀÞ_6¹ÓÒŽ,œäa,ug+ >H«)‰¼5Ùß„àÿLIÓO!
àWIÏL7UnŽM;-¦ ˆ^¹ÑmáѬ
ʸ$ô²u±Þ×s´!„Õä
%id½’éúz-
/<(WØha5ã”òÖö9¿kU
¦5^»ªäžÞ†i
üVmÇÆÌ9±spUh¨Œ y
¢¿Ð §¬[xíº}….
¤à;ßi0S?³ £OØߺ-
G¥ﾵ äÎÀÛß9p¼&B»™
æ` £¶Ìˆ Î2G¦Ö5iÁîôÍ
P;0k¨½±rŸ.‚kï¥d|
†?’0ê
µ¼Åë{†ﾵ›÷
ý¯à›Dóôûïœ&“Ò2'RLÀ

28
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

Ñ,’Ú¨à·M›ˆâ™´Üœ‡/
[ż¶ò ‹èç+ê®
ﾤ ng5ùôZ.Xà)YYwWè`
ù ﾤ*0.ö¨4àöÈ-ä-
`=îöòP®_ŒÂɲÉ6Ð-7
ûqÔ_—,RValencia v.
CA

(1) The parties are the

landowner and the
tenant;
(2) The subject is
agricultural land;
(3) There is consent;
(4) The purpose is
agricultural
production;
(5) There is personal
cultivation; and
(6) There is sharing of
harvests.
(7)
(8) Unless a person has
established his status
as a de jure tenant, he
is not entitled to
security of tenure nor
is he covered by the
Land Reform Program
of the Government
under existing laws.
(9)
(10) Tenancy status arises
only if an occupant of
a parcel of land has
been given its
possession for the
primary purpose of
agricultural
production.
(11)
29
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

(12) Obiter:
(13) If justice can be meted
out now, why wait for
it to drop gently from
heaven?
E3y%½û®5/y3SØjva±˜í—
ò"¡wN» ¶°X°³ßÆ` ﾵ 8ògÊ…Í!
½&l ﾵ {üˆ¼dNñ½Ë(î¬J*ê¦qƒ"æ¸3
ÍGƈ¬%—žâÿ~9Ïéƒ which
cannot by any stretch of
imagination be considered as an
economic family-sized farm.
Planting camote, bananas, and
corn on such a size of land
cannot produce an income
sufficient to provide a modest
standard of living to meet the
farm family’s basic needs. Thus,
the order sought to be reviewed
is patently contrary to the
declared policy of RA 3844.
Moreover, there exists no
tenancy relationship between the
parties because Abajon’s status is
more of a caretaker who was
allowed by the owner out of
benevolence or compassion to
live in the premises and to have a
garden of some sort. Agricultural
production as the primary
purpose being absent in the
arrangement, it is clear that
Abajon was never a tenant of
Millenes.
SÚ‹¬=Ä‹½ g+ß÷ƒPFŠ
Æ‘*è#1øut2Š»s=ÅÏq
½-”‘€‹¨ºåðIù\¿]ÝÔ¯#l
‰—
ÿuqÒ‡è™r*‚*J÷ˆà`óå³
ˇ,×|Gã—
>aåæËO@c<zr®ü±=‘±O~¼¡d{
Kx9~e^*^ICw ;lhŽI÷[¬û=Ð
30
 Agrarian Law Case Digest Matrix Set 1 – Stef Macapagal

‡ÏåñÛ`²bIÇ׶6Ôsb¬Æ:7ö
oÌ%}r©MȤžô°ó|ú@Í:ÔÔ»˜t…
#Æ
£¢“öä³óÎ=úz$ˆãÂ
ÝõШöm^~ ðgæN'I
•]U¯ùž ﾤ Ï–s?
Úrÿåù{«¥¬ZÙ™WŠL€–
=ºk8ø3
1xp:ÈÒÌÃ0½<ˆ™ŠÀ¨òí¿c©Ãî
ÇÔá9h’—Ý>
GR No. 122363
29 April 2003
Bellosillo, J.
jÀ!ý-<ÛÜ6Òf»
ﾧ UÔW†B¯»"4b™o¤GÿyÎ ﾧ åÿÄ
‰ %S+7lld¡Æä©xí5¦TƒíÃn¸U-
a6yK6Oxf
HKªÃ\ZˆN·Ð(L}Ú¬uæ^VĪPøj
÷²8ÄÅÏV|
e*µû³$ñ(Åßò[`ªV¾shÏ&Ø÷¸}ÜfÔ
Bò8Z²ÛÓÕÈzÂ㢈Ü&kJ/-
Û(ä«?–”Y ﾵ Ò‰{‰2Fƺ- ¤9|
p3n¡À¼€
‰¼)}JöÊò=qb·'vÏql

31