De Romero v. Court of Appeals
REITERATIONFacts
The Antecedents: The subject property was previously litigated in two civil cases involving the heirs of the late spouses Eugenio Romero and Teodora Saltiga. Petitioners in Civil Case No. 591 alleged that Lutero Romero fraudulently procured a homestead patent over the property, which was allegedly held in trust for the heirs of Eugenio. They also alleged that Lutero sold the property to respondents in Civil Case No. 1056. The RTC ruled in favor of Lutero, declaring the sales void. The CA affirmed. The Supreme Court, in De Romero v. CA, declared Lutero the lawful owner, finding that Eugenio never owned the property and that the sales were void for violating the five-year prohibition on alienation of homesteads. Procedural History: After the De Romero v. CA decision became final, the Heirs of Lutero sought execution. Respondent Sombrino intervened, claiming to be a tenant since 1952, installed by the Sps. Romero. The RTC allowed her intervention but ultimately ordered the execution of the writ, leading to Sombrino's ouster. Sombrino then filed a complaint for illegal ejectment and recovery of possession before the PARAD, alleging tenancy. The PARAD ruled in favor of Sombrino, declaring her a de jure tenant and ordering her reinstatement. The DARAB affirmed, citing Section 10 of R.A. No. 3844, which states that leasehold relations are not extinguished by sale or transfer. The CA also affirmed, finding that Sombrino sufficiently established the elements of tenancy. The Petition: The Heirs of Lutero filed a Petition for Review before the Supreme Court, questioning the existence of an agricultural leasehold tenancy relationship between them and Sombrino.
Issue(s)
Whether there exists an agricultural leasehold tenancy relationship between the petitioners Heirs of Lutero and respondent Sombrino. Whether respondent Sombrino is a de jure tenant entitled to security of tenure.
Ruling
The Petition is meritorious. The assailed Decision and Resolution of the Court of Appeals are REVERSED AND SET ASIDE. The Decision of the PARAD and the Decision of the DARAB are REVERSED AND SET ASIDE. The Complaint for Illegal Ejectment and Recovery of Possession in DARAB Case No. X-543-LN-2005 is DISMISSED.
Ratio Decidendi
On the issue of whether there exists an agricultural leasehold tenancy relationship between the petitioners Heirs of Lutero and respondent Sombrino: The Court finds that respondent Sombrino failed to discharge her burden of proving that a tenancy relationship existed between her and the Sps. Romero. The existence of a tenancy relation is not presumed and requires the presence of six indispensable elements: (1) the parties are the landowner and the tenant; (2) the subject matter is agricultural land; (3) there is consent between the parties; (4) the purpose is agricultural production; (5) there is personal cultivation by the tenant; and (6) the harvest is shared. The absence of any of these requisites negates a de jure tenancy status. In this case, Sombrino's evidence, such as joint affidavits of alleged hired planters and certifications from a BARC Chairman, were deemed insufficient and self-serving. Jurisprudence holds that mere occupation or cultivation of land does not automatically confer tenant status, and certifications from administrative agencies are merely provisional and not conclusive on courts without corroborating evidence. Furthermore, the acknowledgment receipts for irrigation fees and rentals only established an arrangement with Lucita, not with the Sps. Romero, and thus did not prove installation as a tenant by the original landowners. The Court also noted the impossibility of Eugenio Romero, who died in 1948, installing Sombrino as a tenant in 1952, casting further doubt on the alleged tenancy agreement. On the issue of whether respondent Sombrino is a de jure tenant entitled to security of tenure: Even assuming, for the sake of argument, that a tenancy agreement was entered into in 1952, it would still be invalid because it was not created with the true and lawful landowner. The final and executory Decision in De Romero v. CA definitively established that the Sps. Romero never owned the subject property. Eugenio Romero was disqualified from acquiring a homestead patent, and thus, the land could not have passed to him or his heirs. Lutero Romero was declared the true and lawful owner by virtue of his validly acquired homestead patent. Since the Sps. Romero were neither owners, lessees, usufructuaries, nor legal possessors of the subject property, they lacked the legal capacity to install respondent Sombrino as a leasehold tenant. Consequently, any tenancy agreement purportedly entered into by them would be void ab initio, as it was not with the lawful landowner. Therefore, respondent Sombrino cannot be considered a de jure tenant entitled to security of tenure under existing tenancy laws, and the PARAD and DARAB acted beyond their jurisdiction in ordering her reinstatement.
Main Doctrine
The existence of an agricultural leasehold tenancy relationship requires the presence of all indispensable elements, including the consent of the true and lawful landowner. Without proof of such consent and the other essential elements, an occupant or cultivator is not a de jure tenant entitled to security of tenure.