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HEIRS OF NICOLAS JUGALBOT v. CA

This case has been cited 8 times or more.

	GR No. 169913 2011-06-08	HEIRS OF DR. JOSE DELESTE v. LAND BANK OF PHILIPPINES VELASCO JR., J.
We agree with petitioners. The importance of an actual notice in subjecting a property under the agrarian reform program cannot be underrated, as non-compliance with it trods roughshod with the essential requirements of administrative due process of law.[60] Our ruling in Heirs of Jugalbot v. CA[61] is particularly instructive: Firstly, the taking of subject property was done in violation of constitutional due process. The Court of Appeals was correct in pointing out that Virginia A. Roa was denied due process because the DAR failed to send notice of the impending land reform coverage to the proper party. The records show that notices were erroneously addressed and sent in the name of Pedro N. Roa who was not the owner, hence, not the proper party in the instant case. The ownership of the property, as can be gleaned from the records, pertains to Virginia A. Roa. Notice should have been therefore served on her, and not Pedro N. Roa.
	GR No. 179844 2011-03-23	EMERSON B. BAGONGAHASA v. JOHANNA L. ROMUALDEZ NACHURA, J.
It must be borne in mind that this Court is not merely a Court of law but of equity as well. Justice dictates that the DAR Secretary must determine with deliberate dispatch whether indeed no notice of coverage was furnished to respondents and payment of just compensation was unduly withheld from them despite the fact that the assailed CLOAs were already registered, on the premise that respondents were unaware of the CARP coverage of their properties; hence, their right to protest the same under the law was defeated. Respondents' right to due process must be equally respected. Apropos is our ruling in Heir of Nicolas Jugalbot v. Court of Appeals:[24]
	GR No. 172287 2010-01-15	WELFREDO CENEZE v. FELICIANA RAMOS NACHURA, J.
In resolving this petition, the Court is guided by the principle that tenancy is not purely a factual relationship dependent on what the alleged tenant does upon the land; it is also a legal relationship.[11] A tenancy relationship cannot be presumed. There must be evidence to prove the presence of all its indispensable elements, to wit: (1) the parties are the landowner and the tenant; (2) the subject is agricultural land; (3) there is consent by the landowner; (4) the purpose is agricultural production; (5) there is personal cultivation; and (6) there is sharing of the harvest.[12] The absence of one element does not make an occupant of a parcel of land, its cultivator or planter, a de jure tenant.[13]
	GR No. 154048 2009-11-27	STANFILCO EMPLOYEES AGRARIAN REFORM BENEFICIARIES MULTI-PURPOSE COOPERATIVE v. DOLE PHILIPPINES BRION, J.
We have always held that tenancy relations cannot be presumed. The elements of tenancy must first be proved by substantial evidence which can be shown through records, documents, and written agreements between the parties. A principal factor, too, to consider in determining whether a tenancy relationship exists is the intent of the parties.[29]
	GR No. 177667 2008-09-17	CLEODIA U. FRANCISCO v. SPS. JORGE C. GONZALES AND PURIFICACION W. GONZALES AUSTRIA-MARTINEZ, J.
To begin with, the RTC should not have ignored that TCT No. 167907 is in the name of "Cleodualdo M. Francisco, married to Michele U. Francisco." On its face, the title shows that the registered owner of the property is not Matrai and Michele but Cleodualdo, married to Michele. This describes the civil status of Cleodualdo at the time the property was acquired.[17]
	GR No. 176942 2008-08-28	NICORP MANAGEMENT v. LEONIDA DE LEON YNARES-SATIAGO, J.
That respondent was allowed to cultivate the property without opposition, does not mean that the De Leon sisters impliedly recognized the existence of a leasehold relation with respondent. Occupancy and continued possession of the land will not ipso facto make one a de jure tenant.[30] The principal factor in determining whether a tenancy relationship exists is intent. Tenancy is not a purely factual relationship dependent on what the alleged tenant does upon the land but is, moreso, a legal relationship.[31] Thus, the intent of the parties, the understanding when the farmer is installed, and their written agreements, provided these are complied with and are not contrary to law, are more important.[32]
	GR No. 172146 2008-07-30	CORNES v. LEAL REALTY CENTRUM CO. CHICO-NAZARIO, J.
Neither was it shown to the satisfaction of this Court that there existed a sharing of harvests in the context of a tenancy relationship between petitioners and/or their predecessors-in-interest and JOSEFINA. Jurisprudence is illuminating to the effect that to prove such sharing of harvests, a receipt or any other evidence must be presented.[42] None was shown. No receipts were presented as testaments to the claimed sharing of harvests. The only evidence submitted to establish the purported sharing of harvests was the testimony of petitioner Rodolfo Cornes. The sharing arrangement cannot be deemed to have existed on the basis alone of petitioner Rodolfo Cornes's claim. It is self-serving and is without evidentiary value. Self-serving statements are deemed inadequate; competent proof must be adduced.[43] If at all, the fact alone of sharing is not sufficient to establish a tenancy relationship.[44]