Lumayog v. Pitcock
REITERATIONFacts
The Antecedents: Respondents Spouses Leonard and Corazon Pitcock are the registered owners of a parcel of land where they constructed perimeter fences and buildings, including a barn/stable for their racehorses. They employed Manuel A. Lumayog, Sr. as a groom, who was later replaced by his son. On September 22, 2000, respondents filed an unlawful detainer case against petitioner Manuel A. Lumayog, Sr., his wife, and nine children, for their refusal to vacate a portion of the barn/stable used as temporary quarters, despite demand. Respondents alleged that petitioner's employment was terminated in March 2000, and his occupancy was temporary and subject to vacation upon termination of employment or need by respondents. Petitioner and his family claimed a tenancy relationship existed, alleging petitioner ceased to be a paid laborer in 1992 and was made to work as a tenant, planting fruit-bearing trees. They also claimed some of their children did not reside on the property and that the court lacked jurisdiction due to the alleged tenancy. Procedural History: The Municipal Trial Court in Cities (MTCC) ruled in favor of the respondents, ordering the defendants to vacate the barn/stable, pay rent of ₱1,000.00 per month from September 22, 2000, and pay attorney's fees. The MTCC found no tenancy relationship, stating the occupancy was by mere tolerance and could be lawfully terminated. The Regional Trial Court (RTC) affirmed the MTCC decision. The Court of Appeals (CA) also affirmed the RTC decision, noting petitioner's failure to present evidence of tenancy and the stipulation that the property was used for commercial livestock, including racehorses. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a petition for review on certiorari before the Supreme Court, raising issues on the existence of a tenancy relationship and whether a supervening event, the grant of a Certificate of Land Ownership Award (CLOA) to him, would exempt him from Rule 70 of the Rules of Court. Petitioner argued that a DAR Order dated June 15, 2004, denying the exclusion of the property from CARP coverage, implied his tenant status, and that he was subsequently granted a CLOA. Respondents countered that the issues were moot and academic due to a subsequent CA decision in another case (CA-G.R. SP No. 97763) which declared the landholding exempt from CARP coverage as it was not agricultural land, a ruling affirmed by the Supreme Court in G.R. No. 186986.
Issue(s)
Whether a tenancy relationship existed between the parties. Whether the supervening event of granting a Certificate of Land Ownership Award (CLOA) to the petitioner exempts him from the coverage of Rule 70 of the Revised Rules of Court.
Ruling
The petition is DENIED for lack of merit. The decision of the Court of Appeals in CA-G.R. SP No. 74482 dated March 30, 2005, and its Resolution dated September 6, 2005, are hereby AFFIRMED.
Ratio Decidendi
On the issue of tenancy relationship: The Court reiterated that the existence of a tenancy relationship is a question of fact that requires substantial evidence. The petitioner failed to present any concrete evidence to establish such a relationship, relying instead on self-serving statements. The Court noted that the essential elements of tenancy, as defined in Section 5(a) of Republic Act No. 1199, were not met. The parties stipulated that the respondents constructed buildings, including a barn/stable for racehorses, on their property, which was devoted to commercial livestock. The MTCC correctly found that the occupancy of the barn/stable by the petitioner and his family was by mere tolerance of the respondents, and thus, could be lawfully terminated under Section 1, Rule 70 of the Rules of Court. The factual findings of the lower courts and the Court of Appeals that no tenancy relationship existed were conclusive upon the Supreme Court, as it is not a trier of facts. On the effect of the Certificate of Land Ownership Award (CLOA): The Court held that the supervening event of the grant of a CLOA to the petitioner did not exempt him from the coverage of Rule 70 of the Rules of Court. This is because the premises involved in the unlawful detainer case was the barn/stable, which was distinct from the area the petitioner claimed to be tilling. Furthermore, a subsequent Court of Appeals decision in CA-G.R. SP No. 97763, which was affirmed by the Supreme Court, declared the subject landholding exempt from CARP coverage as it was not agricultural land but was devoted to livestock raising. This ruling rendered the petitioner's claim of tenancy and subsequent ownership of a portion of the land moot and academic in the context of the ejectment case concerning the barn/stable.
Main Doctrine
The existence of a tenancy relationship is a question of fact that requires substantial evidence, and self-serving statements are insufficient to establish it. Furthermore, the subsequent grant of a Certificate of Land Ownership Award (CLOA) does not automatically exempt a party from an unlawful detainer case concerning a property not considered agricultural land.