Hilario v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: Salvador Baltazar filed a complaint alleging he had been a continuous share tenant since January 1955 on a two-hectare land previously owned by Socorro Vda. de Balagtas. He claimed the spouses Bonifacio and Eduarda Hilarios threatened him to desist from cultivating a 4,000 square meter portion of the land and intended to fence it. Procedural History: The Court of Agrarian Relations (CAR) initially ruled that the land was not agricultural but plain 'bakuran,' thus Baltazar was not a tenant. The Court of Appeals (CA) remanded the case for further proceedings. After admitting additional evidence, the CAR again ruled that no tenancy relationship existed and ordered Baltazar's ejectment. Baltazar appealed to the Intermediate Appellate Court (IAC), which reversed the CAR's decision, declaring Baltazar a leasehold tenant entitled to security of tenure. The Petition: The spouses Hilarios filed a petition for review on certiorari, assailing the IAC's decision for disturbing the CAR's findings of fact and for substituting its own findings.
Issue(s)
Whether the respondent Court of Appeals erred in disturbing the findings of facts and decision of the Court of Agrarian Relations. Whether the respondent Court of Appeals erred in substituting its own findings of facts for those of the Court of Agrarian Relations. Whether the respondent Court of Appeals erred in not affirming the decision of the Court of Agrarian Relations, finding the lots in question with an area of 1,740 square meters as residential and the private respondent not to be a tenant.
Ruling
The petition is GRANTED. The decision of the respondent Court of Appeals is REVERSED and SET ASIDE, and the decision of the Court of Agrarian Relations is AFFIRMED.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in disturbing the findings of fact of the Court of Agrarian Relations: The Supreme Court found no valid reason to deviate from the findings of the CAR. The evidence presented by the petitioners sufficiently established that private respondent Salvador Baltazar is not a tenant of the landholding in question. The CAR's finding that the land is residential and not agricultural, and that Baltazar is not a tenant, was supported by substantial evidence. The Court emphasized that the nature of the disputed property is the key factor in ascertaining the existence of a landowner-tenant relationship. On the issue of whether the Court of Appeals erred in substituting its own findings of fact for those of the Court of Agrarian Relations: The Supreme Court agreed with the respondent court that it can affirm on appeal the findings of the CAR only if there is substantial evidence to support them. However, after a careful consideration of the records, the Court found no valid reason to deviate from the CAR's findings. The evidence presented by the petitioners was deemed more than sufficient to justify the conclusion that Baltazar is not a tenant. The IAC's reversal was based on speculative and conjectural conclusions, contrary to the substantial evidence on record. On the issue of whether the Court of Appeals erred in not affirming the decision of the Court of Agrarian Relations, finding the lots in question as residential and the private respondent not to be a tenant: The Supreme Court held that the requisites for the existence of a tenancy relationship were not met. These requisites are: (1) the parties are the landholder and tenant; (2) the subject is agricultural land; (3) the purpose is agricultural production; and (4) there is consideration. The Court noted that the land in question, with an area of 1,740 square meters, is located in the poblacion of San Miguel, Bulacan, and was classified as residential by the PNB's inspection and appraisal report, the deed of sale, and the tax declarations. Furthermore, the alleged tenant, Baltazar, is a full-time government employee and pays no rental or share to the landowners. The former owner, Corazon Pengson, testified that she did not receive any share from the produce and that she knew she was no longer the owner since 1974 when the property was foreclosed. The Court reiterated that tenancy is a legal relationship that requires the consent of the true and lawful landholder, not by imposition or usurpation.
Main Doctrine
The requisites for the existence of a tenancy relationship, namely: (1) the parties are the landholder and tenant; (2) the subject is agricultural land; (3) the purpose is agricultural production; and (4) there is consideration, must all be met. The absence of one or more requisites does not make the alleged tenant a de facto tenant as contra-distinguished from a de jure tenant, who is entitled to security of tenure.