FRANCISCO LANDICHO, FEDERICO LANDICHO AND BUENAVENTURA LANDICHO, PETITIONERS, VS. FELIX SIA, RESPONDENT.

Landicho versus Sia

The Case

This is a petition for review on certiorari brought by Francisco Landicho, Federico Landicho, and Buenaventura Landicho against Felix Sia, arising from a complaint for the fixing and payment of disturbance compensation and the award of a home lot. The petitioners claim to be tenants of three parcels of agricultural land in Tayabas, Quezon, which the respondent purchased and later converted into a residential subdivision. The case matters because it gathers into one decision the essential requisites of an agricultural tenancy relationship, the rule that tenancy is never presumed, and the teaching that a farm helper within the tenant's immediate farm household does not thereby become a tenant.

Procedural History

The petitioners first sought the assistance of the Barangay Agrarian Reform Committee, whose chairman brought the matter to the Provincial Agrarian Reform Office of Quezon. The Provincial Legal Officer found that Francisco was the bona fide tenant but had voluntarily surrendered his tenancy rights twice, and that Federico and Buenaventura were mere farm helpers. A second protest before the Regional Legal Division of Region Four in Pasig was likewise dismissed, and the Regional Director confirmed in a letter that only Francisco was the legitimate tenant and that he had surrendered his rights.

The petitioners then filed a complaint before the Department of Agrarian Reform Adjudication Board. The Provincial Adjudicator of Region Four ruled in their favor, awarding disturbance compensation, a home lot of 200 square meters each, and damages. On appeal, the DARAB affirmed in part but deleted the award of disturbance compensation on the finding that the petitioners remained bona fide tenants. Felix Sia then filed a petition for review with the Court of Appeals, which set aside the DARAB decision and dismissed the complaint, holding that no tenancy relationship existed and that, in any event, the cause of action had prescribed. The Court of Appeals denied reconsideration, and the petitioners came to the Supreme Court by petition for review on certiorari.

Facts

Three parcels of agricultural land in Barangay Mateona, Tayabas, Quezon, with an aggregate area of about 27,287 square meters, were originally owned by the Aragons. The land was tenanted by the late Arcadio Landicho from 1949 until his death in 1972, after which his son Francisco succeeded to the tenancy rights. Federico, Francisco's brother, and Buenaventura, Francisco's son, helped him cultivate the land.

On January 31, 1976, Francisco executed a notarized deed of surrender of his tenancy rights in favor of Eloisa Zolota, wife of Alberto Aragon, for a consideration of 1,000 pesos. Notwithstanding that deed, the petitioners continued cultivating the landholdings until 1987, when Francisco executed a second notarized deed of surrender in favor of the Aragons for 3,000 pesos. On the same day, the Aragons sold the three parcels to the respondent Felix Sia for 50,000 pesos.

Sia converted the land into a residential subdivision without a clearance from the Department of Agrarian Reform and ejected the petitioners. The petitioners alleged that the deeds of surrender were invalid because Francisco, then illiterate and advanced in age, was made to sign them through insidious words and undue influence. The Aragons and Sia maintained that the deeds were written in Tagalog, a language Francisco understood, and were voluntarily executed.

Issues

• Whether or not the petitioners are bona fide tenants of the land purchased by the respondent.
• Whether or not the cause of action of the petitioners had already prescribed at the time of the filing of the complaint.

Applicable Provisions

Section 5, paragraph a, of Republic Act Number 1199, the Agricultural Tenancy Act of the Philippines, defines a tenant:

A tenant is a person who, himself and with the aid available from within his immediate farm household, cultivates the land belonging to, or possessed by, another, with the latter's consent for purposes of production, sharing the produce with the landholder under the share tenancy system, or paying to the landholder a price certain or ascertainable in produce or in money or both, under the leasehold tenancy system.

This definition supplies the elements the Court requires, and it is the consent of the landholder, expressly written into the definition, that the Court finds missing as to Federico and Buenaventura.

Ruling

On the first issue, the Court denied the petition and agreed with the Court of Appeals. It first noted that whether the petitioners are tenants is essentially a question of fact, ordinarily improper in a petition under Rule 45, but it examined the records because the findings of the DARAB and the Court of Appeals contradicted each other. The Court then drew a distinction between Francisco, on the one hand, and Federico and Buenaventura, on the other.

As to Francisco, both sides agreed that the Aragons recognized him as a bona fide tenant when he continued cultivating the land after his father's death. The dispute turned on the validity of the two deeds of surrender, and the Court upheld the finding that he had voluntarily surrendered his tenancy rights, thereby extinguishing the tenancy relationship.

As to Federico and Buenaventura, the Court held that not all the requisites of a tenancy relationship were present. The Court laid them down as follows: the parties are the landowner and the tenant; the subject matter is agricultural land; there is consent between the parties; the purpose is agricultural production; there is personal cultivation by the tenant; and there is sharing of the harvests between the parties. The essential element of consent was absent, because the landowners never recognized Federico and Buenaventura as legitimate tenants. Both deeds of surrender mentioned only Francisco as tenant. Their claim rested on self-serving statements, and the Court held that independent and concrete evidence is needed to prove personal cultivation, sharing of harvests, or the consent of the landowner. A tiller or farmworker does not automatically become an agricultural tenant by mere occupation or cultivation. The Court also held that the existence of a tenancy relationship cannot be presumed, and that a claim of tenancy does not by itself give rise to security of tenure. It found the DARAB's inferences purely speculative, and it sustained the finding that Federico and Buenaventura were farm helpers within Francisco's immediate farm household.

On the second issue, having found that no tenancy relationship existed and that Francisco had surrendered his rights, the Court found no cause of action in favor of the petitioners, and it denied the petition.

Doctrine

A tenancy relationship is never presumed. One who claims the status of tenant must prove all of its essential requisites by independent and concrete evidence, not by self-serving statements: that the parties are the landowner and the tenant; that the subject matter is agricultural land; that there is consent between the parties; that the purpose is agricultural production; that there is personal cultivation by the tenant; and that there is sharing of the harvests. Consent of the landowner is indispensable, and it is written into the statutory definition of a tenant under Section 5 of Republic Act Number 1199, which requires cultivation of another's land with the latter's consent. A tiller or farmworker does not become an agricultural tenant by mere occupation or cultivation, and members of the tenant's immediate farm household who merely help him cultivate do not acquire tenancy rights of their own. Security of tenure flows only from a duly established tenancy relationship.

Disposition

The petition was denied, and the decision of the Court of Appeals dismissing the complaint was upheld, so the respondent Felix Sia prevailed.

Remember This

Memorize the six requisites of tenancy and the rule that tenancy is never presumed, for consent of the landowner is the element examiners love to test. This case is a favorite for questions on farm helpers within the immediate farm household and on why a tiller does not automatically become a tenant.