San Diego v. Evangelista
REITERATIONFacts
The Antecedents: Petitioner Monico San Diego was an agricultural tenant on a parcel of land owned by Andres Evangelista, father of respondent Eufrocinio Evangelista. After Andres' death, respondent inherited the property. Petitioner filed a complaint against respondent before the DARAB, alleging that respondent forcibly entered the bamboo-planted portion of the property, cut bamboo trees he had planted, and threatened to dispossess him as an agricultural tenant. Respondent countered that petitioner was only a tenant of the riceland portion and denied petitioner's claim of planting the bamboo trees, stating they had existed since 1937. Procedural History: The DARAB Provincial Adjudicator dismissed petitioner's complaint, finding that the contract of lease only covered the riceland portion. The DARAB reversed this decision, holding that the agricultural leasehold contract covered the entire 3-hectare land, including the bamboo portion, and that doubts should be resolved in favor of the tenant. The Court of Appeals reversed the DARAB, reinstating the Provincial Adjudicator's decision, and held that the essential elements of tenancy, specifically personal cultivation and sharing of harvest, were wanting with respect to the bambooland. The Petition: Petitioner filed a petition for review on certiorari with the Supreme Court, insisting that the Agricultural Leasehold Contract with respondent's father covered the entire 3-hectare property.
Issue(s)
Whether the Agricultural Leasehold Contract between petitioner and respondent's father covers the entire 3-hectare property, including the portion planted with bamboo. Whether a tenancy relationship exists between petitioner and respondent with respect to the bambooland portion of the property.
Ruling
The petition is DENIED. The decision of the Court of Appeals dated December 18, 2003 is AFFIRMED.
Ratio Decidendi
On the issue of whether the Agricultural Leasehold Contract covers the entire 3-hectare property, including the portion planted with bamboo: The Court held that the literal meaning of the contract's stipulations must control if the terms are clear and leave no doubt upon the intention of the parties, pursuant to Article 1370 of the New Civil Code. Paragraph 1 of the contract referred to a "farm lot which is a portion" of the parcel of land, consisting of 3.00 hectares. However, paragraphs 2 and 4 of the contract specified that the land was devoted to the production of "palay crop(s)" and that the rental was based on the yield of "palay." The contract did not mention bamboos or the bambooland portion. This specificity regarding palay production and rental, coupled with the omission of bamboo, indicated that the parties' intention was to leasehold only the riceland portion. Furthermore, acts contemporaneous and subsequent to the contract's execution showed that the parties intended a tenancy relationship only for the rice-planted portion. Petitioner consistently paid rentals in palay, not bamboo, and the list of harvests and payments from 1981 to 1994 reflected payments consistent with the 33 cavans of palay stipulated in the contract for the wet season, further supporting the interpretation that the contract was limited to the riceland. On the issue of whether a tenancy relationship exists between petitioner and respondent with respect to the bambooland portion of the property: The Court reiterated the essential elements of a tenancy relationship as laid down in Monsanto v. Zerna: (1) the parties are landowner and tenant; (2) the subject matter is agricultural land; (3) there is consent; (4) the purpose is agricultural production; (5) there is personal cultivation by the tenant; and (6) the harvest is shared between the landowner and the tenant. Applying these elements, the Court found that requisites 5 and 6 were wanting with respect to the bambooland. The contract itself, by pertaining only to the produce of rice, belied petitioner's claim of personal cultivation of bamboo trees. No evidence of personal cultivation of bamboo trees was presented by petitioner, other than his bare allegations. On the contrary, affidavits from neighbors, including a Barangay Chairman, established that Andres Evangelista was in possession of the bambooland as early as 1957 and administered the cutting of bamboo trees, a practice continued by respondent after Andres' death. The Court also noted the Adjudicator's observation that it was unlikely for a person of petitioner's age to claim planting the bamboo trees. Moreover, the annual payments of lease, as evidenced by the handwritten list, corresponded only to the yield of rice, not the disputed bamboo land. Absent the essential elements of consent and sharing between the parties concerning the bambooland, no tenancy relationship could exist for that portion.
Main Doctrine
The existence of a tenancy relationship requires the presence of all its essential elements, namely: (1) the parties are landowner and tenant; (2) the subject matter is agricultural land; (3) there is consent; (4) the purpose is agricultural production; (5) there is personal cultivation; and (6) the harvest is shared. The absence of any of these elements, particularly personal cultivation and sharing of harvest, negates the existence of a tenancy relationship.