In Primitivo Macalanda, Jr. v. Atty. Roque A. Acosta, the Supreme Court affirmed that a mere claim of being a tenant does not automatically grant rights under agrarian law. The Court reiterated that to establish a tenancy relationship, specific elements like consent of the landowner and sharing of harvest must be proven with substantial evidence. This ruling underscores the importance of presenting concrete proof when asserting rights as a tenant, preventing mere occupants from claiming agrarian protection without basis.

From Caretaker to Tenant: The Imperative of Proving Agrarian Ties

This case revolves around a dispute over land in Pangasinan between Primitivo Macalanda, Jr. (Petitioner) and Atty. Roque A. Acosta (Respondent). The Petitioner claimed to be a tenant of the Respondent’s land, while the Respondent asserted that the Petitioner was merely a caretaker. The central legal question is whether the elements of a tenancy relationship were sufficiently established to grant the Petitioner rights as a tenant under agrarian law.

The Supreme Court addressed the core issue of whether a tenancy relationship existed between Macalanda and Acosta. The Court began by emphasizing the limited scope of a Rule 45 petition, which generally confines itself to questions of law. The determination of a tenancy relationship is fundamentally a question of fact, and the findings of the Court of Appeals (CA) and the Department of Agrarian Reform Adjudication Board (DARAB) are typically respected unless there is a clear error.

In the case of Vicente Adriano, v. Alice Tanco, Geraldine Tanco, Ronald Tanco, and Patrick Tanco, the Court defined tenancy relationship as:

Tenancy relationship is a juridical tie which arises between a landowner and a tenant once they agree, expressly or impliedly, to undertake jointly the cultivation of a land belonging to the landowner, as a result of which relationship the tenant acquires the right to continue working on and cultivating the land.

The Court then enumerated the essential elements required to establish a tenancy relationship. These are: (1) the parties are the landowner and the tenant; (2) the subject matter is agricultural land; (3) there is consent between the parties to the relationship; (4) the purpose of the relationship is to bring about agricultural production; (5) there is personal cultivation on the part of the tenant; and (6) the harvest is shared between landowner and tenant. All these elements must be proven by substantial evidence. The absence of even one element means there is no de jure tenancy. This is crucial because only a de jure tenant is entitled to security of tenure and coverage under the Land Reform Program.

The Supreme Court highlighted that the burden of proving the existence of a tenancy relationship rests on the party claiming to be a tenant. In this case, Macalanda presented a Deed of Agreement to support his claim, arguing that it acknowledged his status as a tenant. However, the Court found that the Deed of Agreement was ambiguous, referring to Macalanda as both a “tenant/caretaker.” This ambiguity failed to sufficiently establish the element of consent, which is crucial for creating a tenancy relationship. The court emphasized that additional evidence was needed to demonstrate the landowner’s consent to a tenancy relationship.

Furthermore, the Court noted the absence of evidence showing a sharing of harvest between Macalanda and Acosta. Macalanda claimed to have cultivated the land for 17 years but provided no receipts or other documentation to prove that he shared the harvest with Acosta. The absence of such evidence further weakened his claim of a tenancy relationship. The Court emphasized that occupancy and cultivation alone are not sufficient to establish tenancy; there must be independent and concrete evidence of sharing of harvest or consent of the landowner.

Drawing from the case of Antonio Pagarigan, v. Angelita Yague and Shirley Asuncion, the Court reiterated that:

We have consistently held that occupancy and cultivation of an agricultural land, no matter how long, will not ipso facto make one a de jure tenant. Independent and concrete evidence is necessary to prove personal cultivation, sharing of harvest, or consent of the landowner. We emphasize that the presence of a tenancy relationship cannot be presumed; the elements for its existence are explicit in law and cannot be done away with by mere conjectures. Leasehold relationship is not brought about by the mere congruence of facts but, being a legal relationship, the mutual will of the parties to that relationship should be primordial.

The Supreme Court gave significant weight to the findings of the DARAB and the CA, which both concluded that Macalanda failed to establish the existence of a tenancy relationship. The DARAB, with its expertise in agrarian matters, is given deference by the courts, and its factual findings are considered conclusive and binding unless there is a clear showing of error.

FAQs

What was the key issue in this case?	The key issue was whether a tenancy relationship existed between Primitivo Macalanda, Jr. and Atty. Roque A. Acosta, which would determine Macalanda’s rights to the land. The court examined whether the essential elements of a tenancy relationship were sufficiently proven.
What are the essential elements of a tenancy relationship?	The essential elements include: landowner and tenant as parties, agricultural land as the subject, consent to the relationship, agricultural production as the purpose, personal cultivation by the tenant, and sharing of the harvest. All these elements must be supported by substantial evidence.
Who has the burden of proving a tenancy relationship?	The party claiming to be a tenant has the burden of proving the existence of a tenancy relationship. This requires presenting substantial evidence to support each of the essential elements.
What kind of evidence is needed to prove sharing of harvest?	Evidence such as receipts, accounting records, or testimonies from neutral parties can be used to prove the sharing of harvest. The evidence should clearly demonstrate that the landowner received a portion of the harvest from the tenant.
Can occupancy and cultivation alone establish tenancy?	No, occupancy and cultivation alone are not sufficient to establish a tenancy relationship. Independent and concrete evidence of sharing of harvest or consent of the landowner is necessary.
What is the significance of the DARAB’s findings?	The DARAB (Department of Agrarian Reform Adjudication Board) has expertise in agrarian matters, and its factual findings are given great weight by the courts. Unless there is a clear showing of error, the DARAB’s findings are considered conclusive and binding.
What was the Court’s ruling on the Deed of Agreement presented?	The Court found the Deed of Agreement to be ambiguous because it referred to Macalanda as both a “tenant/caretaker.” This ambiguity was insufficient to establish the element of consent, which is crucial for creating a tenancy relationship.
What is the practical implication of this ruling?	The practical implication is that individuals claiming to be tenants must present concrete evidence to support their claim, particularly regarding consent from the landowner and sharing of harvest. Without such evidence, they cannot claim the rights and protections afforded to tenants under agrarian law.

This case underscores the importance of having clear and convincing evidence when claiming tenancy rights. A mere assertion is not enough; the essential elements of a tenancy relationship must be proven with substantial evidence to avail of the protections under agrarian law.

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: PRIMITIVO MACALANDA, JR. v. ATTY. ROQUE A. ACOSTA, G.R. No. 197718, September 06, 2017