Reyes v. Joson
REITERATIONFacts
The Antecedents: Petitioner Loreto Reyes was hired as a caretaker/watcher of a fishpond in 1963. Over the years, the lease and administration of the fishpond changed hands. Reyes continued to work as a caretaker/watcher under successive lessees and administrators, including Hilarion Caragay, Honorio Joson, and Felizardo Malibiran. During Malibiran's lease from 1984 to 1989, Reyes signed the lease contract as "bantay palaisdaan." In November 1989, Caragay re-entered the fishpond and harvested therefrom with Reyes' assistance, leading Joson to file a forcible entry case. A compromise agreement was reached, but Caragay and his workers, including Reyes, failed to vacate. Procedural History: Reyes filed a petition for injunction with the RTC, which dismissed the case for lack of jurisdiction, citing Section 50 of RA 6657, and conferring primary jurisdiction on the DAR. Subsequently, an alias writ of execution was issued in the forcible entry case, leading to Reyes' ejectment. Reyes then filed a complaint for maintenance of peaceful possession with the PARAD, claiming to be an agricultural tenant. The PARAD declared Reyes a lawful tenant and made the TRO permanent. The DARAB affirmed this decision, ordering reinstatement and payment of damages. The respondents appealed to the Court of Appeals, which reversed the DARAB's decision, holding that Reyes was a mere fishpond watcher and not a tenant, citing the lack of evidence of tenancy and Reyes' own admission in signing the Malibiran lease contract as "bantay palaisdaan." The Petition: The present petition for review on certiorari assails the Court of Appeals' decision, arguing that the DARAB's factual finding of a tenancy relationship should be conclusive.
Issue(s)
Whether the petitioner is an agricultural tenant entitled to security of tenure.
Ruling
The petition is denied. The Decision of the Court of Appeals in CA-G.R. SP No. 41797 dated March 13, 2000, is affirmed in toto.
Ratio Decidendi
On Issue 1: The Court ruled that petitioner Loreto Reyes is not an agricultural tenant but a mere fishpond watcher/caretaker. Applying the requisites established in Laresma v. Abellana, the Court noted that all six elements of tenancy must concur to create a de jure tenancy relationship, and the absence of even one element prevents the occupant from gaining security of tenure. The Court emphasized that consent on the part of the landowner is an essential requisite because the right to hire a tenant is a personal right of the landowner. Citing Berenguer, Jr. v. Court of Appeals, the Court held that there was no proof that the owner, Tomas Aguirre, ever hired or authorized the hiring of Reyes as a tenant. Furthermore, the Court found that Reyes failed to prove the sharing of harvests with the owner through substantial evidence; the mere fact of sharing produce is insufficient because it is common for caretakers to give produce to owners without a tenancy relationship. Finally, the Court observed that Reyes's act of signing a previous lease contract as 'bantay palaisdaan' was an admission that he viewed himself as a watcher rather than a tenant-cultivator. Consequently, since he failed to establish his status as a de jure tenant, he is not entitled to security of tenure under the law.
Main Doctrine
The existence of a tenancy relationship requires the concurrence of all essential elements, including the consent of the landowner and sharing of harvests. Mere occupation or cultivation of agricultural land does not automatically confer the status of a de jure tenant.