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VHJ CONSTRUCTION and DEVELOPMENT CORPORATION v. CA

This case has been cited 6 times or more.

	GR No. 184369 2013-10-23	HEIRS OF FLORENTINO QUILO v. DEVELOPMENT BANK OF PHILIPPINES-DAGUPAN BRANCH SERENO, C.J.
A tenancy relationship is a juridical tie that arises between a landowner and a tenant once they agree, expressly or impliedly, to undertake jointly the cultivation of a land belonging to the landowner, as a result of which relationship the tenant acquires the right to continue working on and cultivating the land.[62] The relationship cannot be presumed.[63] All the requisite conditions for its existence must be proven, to wit: (1) The parties are the landowner and the tenant.
	GR No. 169589 2009-06-16	JOAQUIN SOLIMAN v. PAMPANGA SUGAR DEVELOPMENT COMPANY NACHURA, J.
Petitioners' assertion that they were allowed to cultivate the subject property without opposition, does not mean that PASUDECO impliedly recognized the existence of a leasehold relation. Occupancy and continued possession of the land will not ipso facto make one a de jure tenant, because the principal factor in determining whether a tenancy relationship exists is intent.[53] This much we said in VHJ Construction and Development Corporation v. Court of Appeals,[54] where we held that: Indeed, a tenancy relationship cannot be presumed. There must be evidence to prove this allegation. 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. It is also a legal relationship. As we ruled in Chico v. Court of Appeals[347 SCRA 35 (2000)]:
	GR No. 150305 2007-11-22	HONOFRE FUENTES v. FELOMINO CAGUIMBAL AUSTRIA-MARTINEZ, J.
Except for the sweeping conclusion made by the RTC that respondent continued the tenancy relationship of his father with petitioner, there is no mention of evidence in the decision of the RTC that would sustain its finding that respondent or his predecessor-in-interest is an agricultural tenant of the property in question. It was not shown how respondent or his father was instituted as an agricultural tenant thereof; neither was the existence of a sharing agreement between respondent and petitioner shown. The fact alone of working on another's landholding does not raise a presumption of the existence of agricultural tenancy.[21] In fact, the RTC even noted that there was a standing feud between petitioner and respondent's father over the property. This negates the proposition that there was a consensual institution of respondent or his father as an agricultural tenant of the property.
	GR No. 167748 2005-11-08	HEIRS OF RAFAEL MAGPILY v. HERMINIGILDO DE JESUS YNARES-SANTIAGO, J.
In the present case, the sworn statements of Gregorio Ambrosio and Nestor C. Marinay merely attested to the fact that private respondent became a worker in the coconut plantation of Magpily after the death of the former tenant of the land. Nowhere in the said statements was it mentioned why and how private respondent became an agricultural tenant. Nothing was said about the intent of Magpily to institute private respondent as his tenant nor of the landowner's purpose to embark on agricultural production. Neither did said declarations attest to the existence of a sharing agreement between the parties. Indeed, said statements only tended to prove that private respondent is a worker or an overseer of the land and nothing more. The same is true to Magpily's letter directing private respondent to allow the bearer of the letter to cut down trees in his land. It does not prove that private respondent is an agricultural tenant, but only a caretaker of the land. In VHJ Construction and Development Corporation v. Court of Appeals,[22] it was held that the fact alone of working on another's landholding does not raise a presumption of the existence of agricultural tenancy. There must be substantial evidence on record adequate enough to prove the element of sharing.
	GR NO. 166664 2005-10-20	DOMINGO C. SUAREZ v. LEO B. SAUL YNARES-SANTIAGO, J.
In VHJ Construction and Development Corporation v. Court of Appeals,[17] we held that a tenancy relationship cannot be presumed. There must be evidence to prove the tenancy relations such that all its indispensable elements must be established, 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 harvests. All these requisites are necessary to create tenancy relationship, and the absence of one or more requisites will not make the alleged tenant a de facto tenant.
	GR No. 150106 2004-09-08	AMANDO G. SUMAWANG v. ENGR. ERIC D. DE GUZMAN CALLEJO, SR., J.
In VHJ Construction and Development Corporation v. Court of Appeals,[10] we held that: Indeed, a tenancy relationship cannot be presumed. There must be evidence to prove this allegation. 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. It is also a legal relationship. As we ruled in Chico v. Court of Appeals: "Each of the elements hereinbefore mentioned is essential to create a de jure leasehold or tenancy relationship between the parties. This de jure relationship, in turn, is the terra firma for a security of tenure between the landlord and the tenant. The leasehold relationship is not brought about by a mere congruence of facts but, being a legal relationship, the mutual will of the parties to that relationship should be primordial." 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 even more important.