Lawyerly

GR No. 175098

2015-08-26

ISMAEL V. CRISOSTOMO v. MARTIN P. VICTORIA

LEONEN, J.

Valencia explained that Section 6 of the Agricultural Land Reform Code is a subsequent restatement of a "precursor"[25] provision: Section 8 of Republic Act No. 1199. This precursor reads:SECTION 8. Limitation of Relation. — The relation of landholder and tenant shall be limited to the person who furnishes land, either as owner, lessee, usufructuary, or legal possessor, and to the person who actually works the land himself with the aid of labor available from within his immediate farm household.

GR No. 192270

2015-01-26

IRENE D. OFILADA v. SPS. RUBEN ANDAL AND MIRAFLOR ANDAL

DEL CASTILLO, J.

Evidence is necessary to prove the allegation of tenancy. "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."[44]

GR No. 192026

2014-10-01

AUTOMAT REALTY v. SPS. MARCIANO DELA CRUZ

LEONEN, J.

This court has ruled that "[t]enancy is not a purely factual relationship dependent on what the alleged tenant does upon the land [but] is also a legal relationship."[77] Tenancy relationship cannot be presumed. The allegation of its existence must be proven by evidence, and working on another's landholding raises no presumption of an agricultural tenancy.[78] Consequently, the landowner's consent to an agricultural tenancy relationship must be shown.

GR NO. 185838

2014-02-10

RICARDO V. QUINTOS v. DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD

PERLAS-BERNABE, J.

exception or defense. The rule applies to civil and administrative cases.[46] In this relation, it bears stressing that the right to hire a tenant is basically a personal right of a landowner, except as may be provided by law.[47] Hence, the consent of the landowner should be secured prior to the

GR No. 169589

2009-06-16

JOAQUIN SOLIMAN v. PAMPANGA SUGAR DEVELOPMENT COMPANY

NACHURA, J.

Likewise, the alleged sharing and/or payment of lease rentals was not substantiated other than by the deposit-payments with the LBP, which petitioners characterized as amortizations. We cannot close our eyes to the absence of any proof of payment prior to the deposit-payments with LBP. Not a single receipt was ever issued by Gerry, duly acknowledging payment of these rentals from Ciriaco who, allegedly, personally collected the same from the petitioners. Notably, the fact of working on another's landholding, standing alone, does not raise a presumption of the existence of agricultural tenancy. Substantial evidence necessary to establish the fact of sharing cannot be satisfied by a mere scintilla of evidence; there must be concrete evidence on record adequate to prove the element of sharing. Thus, to prove sharing of harvests, a receipt or any other credible evidence must be presented, because self-serving statements are inadequate.[50]

GR No. 174649

2008-09-26

LEOPOLDO JEREMIAS v. ESTATE OF LATE IRENE P. MARIANO

CHICO-NAZARIO, J.

Claims that one is a tenant do not automatically give rise to security of tenure.[10] The elements of tenancy must first be proved in order to entitle the claimant to security of tenure.[11]

GR No. 164912

2008-06-18

PAG-ASA FISHPOND CORPORATION v. BERNARDO JIMENEZ

REYES, R.T., J.

In Valencia v. Court of Appeals,[35] the Court voided the CA finding of tenancy relations between the landowner and the tenants of the civil law lessee for lack of intent. The Court held in Valencia:The substantive issue to be resolved may be expressed in this manner: Can a contract of civil law lease prohibit a civil law lessee from employing a tenant on the land subject matter of the lease agreement? Otherwise stated, can petitioner's civil law lessee, Fr. Flores, install tenants on the subject premises without express authority to do so under Art. 1649 of the Civil Code, more so when the lessee is expressly prohibited from doing so, as in the instant case?

GR NO. 166401

2006-10-30

PEOPLE v. ALFREDO BON

TINGA, J.

There are principles in statutory construction that will sanction, even mandate, this "expansive" interpretation of Rep. Act No. 9346. The maxim interpretare et concordare legibus est optimus interpretandi embodies the principle that a statute should be so construed not only to be consistent with itself, but also to harmonize with other laws on the same subject matter, as to form a complete, coherent and intelligible system a uniform system of jurisprudence.[75] "Interpreting and harmonizing laws with laws is the best method of interpretation. x x x x This manner of construction would provide a complete, consistent and intelligible system to secure the rights of all persons affected by different legislative and quasi-legislative acts."[76] There can be no harmony between Rep. Act No. 9346 and the Revised Penal Code unless the later statute is construed as having downgraded those penalties attached to death by reason of the graduated scale under Article 71. Only in that manner will a clear and consistent rule emerge as to the application of penalties for frustrated and attempted felonies, and for accessories and accomplices.

GR NO. 144652

2005-12-16

ARCADIO B. DANDOY v. ZACARIAS TONGSON

AUSTRIA-MARTINEZ, J.

Furthermore, the fact that Lot No. 294 is an agricultural land does not ipso facto make it an agrarian dispute within the jurisdiction of the DARAB.[16] For the present case to fall within DARAB jurisdiction, there must exist a tenancy relationship between the parties. An allegation that an agricultural tenant tilled the land in question does not make the case an agrarian dispute.[17]

GR NO. 147081

2005-12-09

PLANTERS DEVELOPMENT BANK v. FRANCISCO GARCIA

CORONA, J.

Sec. 10. Agricultural Leasehold Relation Not Extinguished By Expiration of Period, etc. - The agricultural leasehold relation under this Code shall not be extinguished by mere expiration of the term or period in a leasehold contract nor by the sale, alienation or transfer of the legal possession of the landholding. In case the agricultural lessor sells, alienates or transfers the legal possession of the landholding, the purchaser or transferee thereof shall be subrogated to the rights and substituted to the obligations of the agricultural lessor. (Emphasis supplied) This doctrine is well-settled in jurisprudence. [25]

	GR No. 175098 2015-08-26	ISMAEL V. CRISOSTOMO v. MARTIN P. VICTORIA LEONEN, J.
Valencia explained that Section 6 of the Agricultural Land Reform Code is a subsequent restatement of a "precursor"[25] provision: Section 8 of Republic Act No. 1199. This precursor reads:SECTION 8. Limitation of Relation. — The relation of landholder and tenant shall be limited to the person who furnishes land, either as owner, lessee, usufructuary, or legal possessor, and to the person who actually works the land himself with the aid of labor available from within his immediate farm household.
	GR No. 192270 2015-01-26	IRENE D. OFILADA v. SPS. RUBEN ANDAL AND MIRAFLOR ANDAL DEL CASTILLO, J.
Evidence is necessary to prove the allegation of tenancy. "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."[44]
	GR No. 192026 2014-10-01	AUTOMAT REALTY v. SPS. MARCIANO DELA CRUZ LEONEN, J.
This court has ruled that "[t]enancy is not a purely factual relationship dependent on what the alleged tenant does upon the land [but] is also a legal relationship."[77] Tenancy relationship cannot be presumed. The allegation of its existence must be proven by evidence, and working on another's landholding raises no presumption of an agricultural tenancy.[78] Consequently, the landowner's consent to an agricultural tenancy relationship must be shown.
	GR NO. 185838 2014-02-10	RICARDO V. QUINTOS v. DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD PERLAS-BERNABE, J.
exception or defense. The rule applies to civil and administrative cases.[46] In this relation, it bears stressing that the right to hire a tenant is basically a personal right of a landowner, except as may be provided by law.[47] Hence, the consent of the landowner should be secured prior to the
	GR No. 169589 2009-06-16	JOAQUIN SOLIMAN v. PAMPANGA SUGAR DEVELOPMENT COMPANY NACHURA, J.
Likewise, the alleged sharing and/or payment of lease rentals was not substantiated other than by the deposit-payments with the LBP, which petitioners characterized as amortizations. We cannot close our eyes to the absence of any proof of payment prior to the deposit-payments with LBP. Not a single receipt was ever issued by Gerry, duly acknowledging payment of these rentals from Ciriaco who, allegedly, personally collected the same from the petitioners. Notably, the fact of working on another's landholding, standing alone, does not raise a presumption of the existence of agricultural tenancy. Substantial evidence necessary to establish the fact of sharing cannot be satisfied by a mere scintilla of evidence; there must be concrete evidence on record adequate to prove the element of sharing. Thus, to prove sharing of harvests, a receipt or any other credible evidence must be presented, because self-serving statements are inadequate.[50]
	GR No. 174649 2008-09-26	LEOPOLDO JEREMIAS v. ESTATE OF LATE IRENE P. MARIANO CHICO-NAZARIO, J.
Claims that one is a tenant do not automatically give rise to security of tenure.[10] The elements of tenancy must first be proved in order to entitle the claimant to security of tenure.[11]
	GR No. 164912 2008-06-18	PAG-ASA FISHPOND CORPORATION v. BERNARDO JIMENEZ REYES, R.T., J.
In Valencia v. Court of Appeals,[35] the Court voided the CA finding of tenancy relations between the landowner and the tenants of the civil law lessee for lack of intent. The Court held in Valencia:The substantive issue to be resolved may be expressed in this manner: Can a contract of civil law lease prohibit a civil law lessee from employing a tenant on the land subject matter of the lease agreement? Otherwise stated, can petitioner's civil law lessee, Fr. Flores, install tenants on the subject premises without express authority to do so under Art. 1649 of the Civil Code, more so when the lessee is expressly prohibited from doing so, as in the instant case?
	GR NO. 166401 2006-10-30	PEOPLE v. ALFREDO BON TINGA, J.
There are principles in statutory construction that will sanction, even mandate, this "expansive" interpretation of Rep. Act No. 9346. The maxim interpretare et concordare legibus est optimus interpretandi embodies the principle that a statute should be so construed not only to be consistent with itself, but also to harmonize with other laws on the same subject matter, as to form a complete, coherent and intelligible system a uniform system of jurisprudence.[75] "Interpreting and harmonizing laws with laws is the best method of interpretation. x x x x This manner of construction would provide a complete, consistent and intelligible system to secure the rights of all persons affected by different legislative and quasi-legislative acts."[76] There can be no harmony between Rep. Act No. 9346 and the Revised Penal Code unless the later statute is construed as having downgraded those penalties attached to death by reason of the graduated scale under Article 71. Only in that manner will a clear and consistent rule emerge as to the application of penalties for frustrated and attempted felonies, and for accessories and accomplices.
	GR NO. 144652 2005-12-16	ARCADIO B. DANDOY v. ZACARIAS TONGSON AUSTRIA-MARTINEZ, J.
Furthermore, the fact that Lot No. 294 is an agricultural land does not ipso facto make it an agrarian dispute within the jurisdiction of the DARAB.[16] For the present case to fall within DARAB jurisdiction, there must exist a tenancy relationship between the parties. An allegation that an agricultural tenant tilled the land in question does not make the case an agrarian dispute.[17]
	GR NO. 147081 2005-12-09	PLANTERS DEVELOPMENT BANK v. FRANCISCO GARCIA CORONA, J.
Sec. 10. Agricultural Leasehold Relation Not Extinguished By Expiration of Period, etc. - The agricultural leasehold relation under this Code shall not be extinguished by mere expiration of the term or period in a leasehold contract nor by the sale, alienation or transfer of the legal possession of the landholding. In case the agricultural lessor sells, alienates or transfers the legal possession of the landholding, the purchaser or transferee thereof shall be subrogated to the rights and substituted to the obligations of the agricultural lessor. (Emphasis supplied) This doctrine is well-settled in jurisprudence. [25]

VICTOR G. VALENCIA v. CA