G.R. No. 108941 Case Digest

G.R. No. 108941, July 6, 2000

Reynaldo Bejasa and Erlinda Bejasa

vs CA, Isabel Candelaria and Jamie Dinglasan

Ponente: Pardo

Facts:

This case involves two parcels of land located in Oriental Mindoro owned by Isabel Candelaria. October 1974, Candelaria entered into a 3-year lease agreement with Pio Malabanan wherein Malabanan agreed to clear, clean and cultivate the land, to purchase calamansi, and other seedlings, to attend and care for whatever plants thereon exist, to make the necessary harvest of fruits.

Malabanan, later hired the Bejasas to plant on the land and to clear it. On May 1977, Candelaria gave Malabanan a 6-year usufruct over the land. 1983, Malabanan died. Candelaria constituted Jaime Dinglasan as her attorney-in-fact, having powers of administration over the land.

October 1984, Candelaria entered into a new lease contract with Victoria Dinglasan, Jaime's wife with a 1-year term. On December 1984, Bejasas agreed to pay Victoria rent in consideration of an "pakyaw na bunga" agreement, with a term of 1 year.

After the 1 year period, Victoria demanded for Bejasas to vacate, but Bejasas continued to stay and did not give any consideration for its use, be in rent or share.  Candelarian again entered with a 3-year lease agreement with Dinglasans, and made Jaime her attorney-in-fact again. Jaime then filed a complaint before Commission on the Settlement of Land Problems (COSLAP) seeking for ejectment of Bejasas. COSLAP dismissed the complaint.

Jaime then filed it with RTC for recovery of possession; the case was referred to DAR. DAR certified that ht e case was not proper for trial before the civil courts. Trial court dismissed the complaint of Jaime including the leasehold claim of Bejasas. Bejasas then filed a complaint for confirmation of leasehold and recovery of damages against Candelaria and Jaime.

RTC favored the Bejasas. On appeal, CA reversed the decision saying that (1) there was no tenant relationship, (2) Bejasas are mere overseers and not as permanent tenants, (3) the pakyaw contract have expired, (4) sharing of profits was not proven, (5) the element of personal cultivation was not proven.

Issue: Whether there is tenancy in favor of Bejasas.

Ruling:

There is no tenancy relationship. There was no proof of shared harvests. Between Candelaria (as owner) and the Bejasas, there is no relationship. Candelaria never gave her consent. As to the authority of Dinglasans, they had authority to bind the owner in a tenancy agreement, but there is no proof of such presented.