In Sps. Felino S. Samatra and Charlita Isidro vs. Rita S. Vda. de Pariñas, the Supreme Court addressed the critical element of personal cultivation in establishing agricultural leasehold relationships. The Court ruled that a claimant must prove personal cultivation of the land to qualify as a bonafide agricultural lessee and thus be entitled to rights such as pre-emption or redemption. This decision underscores the importance of direct involvement in agricultural activities for those claiming tenant rights, protecting landowners from unsubstantiated claims.

Lease or Mirage: Unraveling Tenant Rights After Foreclosure in Nueva Ecija

This case revolves around two agricultural lots and a homelot in Sto. Domingo, Nueva Ecija, originally owned by spouses Donato Samatra and Macaria Sana. Their children, Felino Samatra and Rita S. Vda. de Pariñas, became entangled in a legal battle after the properties were mortgaged and subsequently foreclosed. The core legal question is whether Rita, claiming to be an agricultural lessee, had the right to redeem the foreclosed lands, despite her brother Felino’s purchase of the same from the bank.

The timeline of events is crucial. In 1972 and 1973, Donato and Macaria mortgaged their properties to secure loans from the Rural Bank of Sto. Domingo. In January 1975, Donato entered into a “Kasunduang Buwisan sa Sakahan” (agricultural lease agreement) with his daughter, Rita, without the bank’s consent. When the spouses failed to repay their loans, the bank foreclosed the mortgages, and certificates of sale were registered in 1976. Despite the foreclosure, Rita remained in possession of the lands.

Negotiations followed, with the bank initially offering the heirs an opportunity to repurchase the properties. Rita showed interest but eventually discontinued her deposits and closed her account. In 1983, Felino expressed interest in repurchasing the lots, and in July 1984, the bank sold the properties to Felino and his wife, Charlita, who registered the sale and obtained title. Rita then filed an agrarian case, seeking to annul the sale to Felino, claiming rights as an agricultural lessee.

The trial court ruled in favor of Felino, finding that Rita was not a bonafide lessee because she did not prove personal cultivation of the land. On appeal, the Court of Appeals reversed this decision, declaring Rita a bonafide agricultural lessee based on documents presented, including a certification from the Ministry of Agrarian Reform (MAR) and an affidavit from the president of a local farmers’ association. However, the Court of Appeals denied Rita’s right of pre-emption and redemption, affirming the validity of the sale to Felino. The case then reached the Supreme Court.

The Supreme Court scrutinized whether the tenancy contract between Donato and Rita was valid and whether Rita was indeed a bonafide agricultural lessee. The Court cited Article 2130 of the Civil Code, which invalidates any stipulation forbidding the owner from alienating mortgaged property.

Article 2130 of the Civil Code renders void any stipulation forbidding the owner from alienating the immovable mortgaged (pacto de non aliendo) property.

Thus, the Court affirmed the validity of the lease agreement, as the mortgage did not extinguish the owner’s right to dispose of the property. However, the critical issue remained: was Rita a bonafide agricultural lessee?

The essential elements of an agricultural leasehold relationship were reiterated by the Court, emphasizing the necessity of personal cultivation by the agricultural lessee. These elements include: the parties being the landowner and the agricultural lessee; the subject matter being agricultural land; consent between the parties; the purpose of agricultural production; personal cultivation by the lessee; and harvest sharing. The Court focused on whether Rita had sufficiently proven personal cultivation.

The Court found Rita’s evidence insufficient. The “Kasunduang Buwisan sa Sakahan” alone did not prove she was a bonafide lessee. The agreement needed to be supported by evidence of personal cultivation. As the Court emphasized, without personal cultivation, a person cannot be considered a tenant, regardless of any written agreement.

Without the element of personal cultivation, a person cannot be considered a tenant even if he is so designated in the written agreement of the parties.

The MAR certification also fell short, as it merely stated Rita was a registered agricultural lessee without affirming her personal cultivation of the land. The affidavit from the president of the farmers’ association was deemed unreliable due to its ambiguous statements and the fact that the affiant had previously issued a conflicting affidavit stating that the land was untenanted and cultivated by Donato Samatra. The Supreme Court has ruled that mere certifications from association officers cannot establish agricultural leasehold relationships, especially when those certifications are contradictory.

The Court also noted Rita’s advanced age, casting doubt on her ability to personally cultivate the lands. She did not testify or present witnesses to attest to her involvement in caring for the plants. The Court clarified that while possession is important, it does not automatically equate to cultivation. Cultivation requires active involvement in caring for the plants, and there was no evidence that Rita performed such acts. The Court rejected the Court of Appeals’ conclusion that Rita could have been assisted by farm laborers, citing the lack of evidence to support this claim.

Ultimately, the Supreme Court concluded that Rita was not a bonafide agricultural lessee due to her failure to prove personal cultivation. Consequently, the Court reinstated the trial court’s decision, affirming the validity of the sale of the lands to Felino and Charlita. The Court also upheld the award of actual damages to Felino and Charlita for unrealized income from the lands due to Rita’s refusal to surrender possession. However, the award of attorney’s fees and litigation expenses was deleted because the trial court did not adequately justify their grant in its decision, which is a requirement according to jurisprudence.

The matter of attorney’s fees cannot be mentioned only in the dispositive portion of the decision.

The Supreme Court’s decision emphasizes that those claiming rights as agricultural lessees must demonstrate active and direct involvement in cultivating the land. This requirement ensures that landowners are protected from claims based solely on paper agreements or unsubstantiated assertions of tenancy.

FAQs

What was the key issue in this case?	The key issue was whether Rita S. Vda. de Pariñas was a bonafide agricultural lessee of the subject lands, entitling her to rights of pre-emption or redemption. The Supreme Court focused on whether she had proven personal cultivation of the land.
What does ‘personal cultivation’ mean in this context?	‘Personal cultivation’ refers to the agricultural lessee’s direct involvement in caring for the plants, not necessarily limited to plowing but including activities like preparing the seedbed, scattering seeds, and maintaining the land. It requires some general industry on the part of the tenant in caring for the plants.
Why was the “Kasunduang Buwisan sa Sakahan” not enough to prove tenancy?	While the “Kasunduang Buwisan sa Sakahan” established a lease agreement, it did not automatically prove a bonafide agricultural leasehold relationship. The Supreme Court required additional evidence to show that Rita personally cultivated the land, which was lacking in this case.
What was the significance of the conflicting affidavits?	The conflicting affidavits issued by Ponciano Alejo, the president of the Malayang Samahang Nayon, cast doubt on the veracity of Rita’s claim. Since Alejo had previously certified that Donato Samatra was the actual tiller, his later affidavit stating Rita was the tenant was deemed unreliable.
Why were attorney’s fees and litigation expenses disallowed?	The Supreme Court disallowed the award of attorney’s fees and litigation expenses because the trial court did not provide a clear justification for their grant in the body of its decision. According to the New Civil Code and jurisprudence, these awards must be explicitly explained.
What is a pacto de non aliendo?	A pacto de non aliendo is a stipulation in a mortgage contract that prohibits the owner from alienating the mortgaged property. The Civil Code considers such stipulations void, allowing the owner to lease or otherwise dispose of the property despite the mortgage.
What was the effect of the property being mortgaged?	The mortgage did not extinguish the original owners’ title to the property, thus they maintained their right to dispose of their property. It was within their rights when they constituted respondent as an agricultural lessee and the legality of the leasehold contract cannot be validly assailed on this ground.
Who is a bonafide agricultural lessee?	A bonafide agricultural lessee is someone who has been recognized to personally cultivate the land, either by themselves or with the aid of farm laborers. This is in compliance with the five elements to be considered as an agricultural lessee.

This ruling reinforces the necessity of proving actual, hands-on cultivation to claim agricultural tenancy rights, balancing the interests of landowners and tenants. It serves as a reminder that mere possession or formal agreements are insufficient without demonstrable evidence of active agricultural engagement.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: SPS. FELINO S. SAMATRA AND CHARLITA ISIDRO, PETITIONERS, VS. RITA S. VDA. DE PARIÑAS, RESPONDENT., G.R. No. 142958, April 24, 2002