G.R. No. 70736 Case Digest

G.R. No. 70736, March 16, 1987

Bonifacio Hilario and Eduarda Buencamino Hilario

vs Hon. IAC and Salvador Baltazar

Ponente: Gutierrez

Facts:

January 1981, Salvador Baltazar filed a verified complaint with Courts of Agrarian Relation-Bulacan alleging that since January 1955 he had been continuous possession as a share tenant of a parcel of land in Bulacan which was previously owned by Socorro Vda. de Balagtas. Thereafter, the spouses Hilario began to threaten him to desist from entering and cultivating the land.

Baltazar claims that he became sa tenant of Socorro by virtue of a kasunduan executed in 1979. After the death of Socorro, he allegedly gave the share pertaining to the daughter of Socorro Corazon Pengzon. It was only in December 1980 that Baltazar knew that portion of the land was already owned by the Hilarios.

The Hilarios, aver that they acquired the land from the PNB after it had been foreclosed. CAR ruled that the land in question is not an agricultural land but a plain "bakuran". Hence, Baltazar is not a tenant.

CA however remanded the case to the lower court for further proceesings on the ground that the findings of CAR were not supported by substantial evidence. In compliance, CAR admitted additional evidence.

Again, CAR declared Baltazar as non-tenant. Baltazar appealed with IAC, IAC set aside the decision of the CAR  and entitling Baltazar security of tenure on the land. Spouse Hilario then petition for review.

Issue: Whether Baltazar is a tenant.

Ruling:

The evidence presented is more than sufficient to justify the conclusion that Baltazar is not a tenant of the landholding. (a) The kasunduan refers to 2-hectare land, while the landholding is only 4000 sqm. (b) When Socorro died, no new contract was executed. (c) Corazon did not receive any rental or share from the produce of the land.