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CAROLINA LIQUETE GANZON v. CA

This case has been cited 3 times or more.

2009-06-16
NACHURA, J.
Finally, the long period of petitioners' alleged cultivation of the subject property cannot give rise to equitable estoppel.   It should be remembered that estoppel in pais, or equitable estoppel arises when one, by his acts, representations or admissions or by his silence when he ought to speak out, intentionally or through culpable negligence, induces another to believe certain facts to exist and the other rightfully relies and acts on such beliefs so that he will be prejudiced if the former is permitted to deny the existence of such facts. The real office of the equitable norm of estoppel is limited to supplying deficiency in the law, but it should not supplant positive law. The elements for the existence of a tenancy relationship are explicit in the law and these elements cannot be done away with by conjectures.[56]
2004-04-14
CARPIO, J.
Section 3 of Republic Act No. 1199 or The Agricultural Tenancy Act of the Philippines ("RA 1199") defines "agricultural tenancy" as the "physical possession by a person of land devoted to agriculture belonging to, or legally possessed by, another for the purpose of production through the labor of the former and of the members of his immediate farm household, in consideration of which the former agrees to share the harvest with the latter, or to pay a price certain or ascertainable, either in produce or in money, or in both." Under RA 1199, there are two systems of agricultural tenancy established: (1) the share tenancy and (2) the leasehold tenancy.[12]
2003-04-29
BELLOSILLO, J.
This is more imagined than real. In the very recent case of Ganzon v. Court of Appeals, decided 30 July 2002, this Court resolved the issue of whether the private respondents should be considered agricultural tenants of the petitioner.[34] The Court ruled that the respondents were not instituted as agricultural lessees but as civil law lessees of the land. This was evident from the contract of lease executed by the parties. The respondents were neither "impliedly" instituted as tenants nor designated as agricultural lessees by reason alone of the acquiescence by petitioner to the continued possession of the property.