Succession Rights in Agricultural Tenancy: A Key to Security of Tenure

Josefina Arines-Albalante and Juana Arines v. Salvacion Reyes and Israel Reyes, G.R. No. 222768, September 02, 2020

In the lush fields of Camarines Sur, a dispute over a piece of land not only tested the strength of agricultural leasehold laws but also highlighted the importance of succession rights in tenancy agreements. When Josefina Arines-Albalante, a deaf-mute daughter of a tenant, faced forcible ejection from her family’s landholding, the Supreme Court of the Philippines stepped in to clarify her rights under the law. This case underscores the critical need for understanding tenant succession and the protection it offers against illegal dispossession.

The central legal question was whether Josefina, succeeding her father Sergio Arines as tenant, had established a tenancy relationship with the landowner, Salvacion Reyes, and whether she was illegally ejected from the landholding. The outcome of this case could affect countless tenant farmers across the Philippines, emphasizing the importance of legal protections in agricultural leasehold agreements.

Legal Context: Understanding Agricultural Leasehold and Succession Rights

Agricultural leasehold in the Philippines is governed by Republic Act No. 3844, which abolished share tenancy and established a system where tenant farmers are given security of tenure. This law aims to protect farmers from arbitrary eviction and ensure they can continue working the land to sustain their livelihoods.

The concept of succession in tenancy is crucial. According to Section 9 of RA 3844, upon the death of a tenant, the agricultural lessor has the option to choose the successor from among the tenant’s heirs, following a specific order of priority: the surviving spouse, the eldest direct descendant by consanguinity, and then the next eldest descendant or descendants in the order of their age. If the lessor fails to choose within one month, the priority follows the aforementioned order.

Key to this case is the understanding that a tenancy relationship does not end with the death of the tenant. As stated in RA 3844, “The agricultural leasehold relation once established shall confer upon the agricultural lessee the right to continue working on the landholding until such leasehold relation is extinguished.” This ensures continuity and security for the tenant’s family.

To establish a tenancy relationship, six elements must be present: the parties must be the landowner and tenant, the subject must be agricultural land, there must be consent, the purpose must be agricultural production, there must be personal cultivation by the tenant, and the harvest must be shared. These elements are essential for a tenant to claim security of tenure.

Case Breakdown: From Ejection to Supreme Court Victory

Josefina’s journey began when her father, Sergio Arines, passed away in 1997. Sergio had been the tenant of a one-hectare rice holding in Sta. Isabel, Buhi, Camarines Sur, under a lease agreement with Salvacion Reyes. After his death, Josefina, assisted by her sister-in-law Juana Arines, continued to cultivate the land, paying the landowner’s share in kind.

In May 2003, Salvacion verbally demanded that Josefina surrender the land. When Josefina refused, Salvacion and her husband Israel forcibly took over the land. Josefina sought mediation through the Barangay Agrarian Reform Committee (BARC) and the Municipal Agrarian Reform Office (MARO), but to no avail. She then filed a complaint for illegal ejectment with the Provincial Agrarian Reform Adjudication Board (PARAD).

The PARAD ruled in Josefina’s favor, ordering her reinstatement and compensation for lost production. Salvacion appealed to the Department of Agrarian Reform Adjudication Board (DARAB), which affirmed the PARAD’s decision. However, the Court of Appeals (CA) reversed these decisions, ruling that Josefina had not established her right to tenancy.

The Supreme Court, in its ruling, emphasized the importance of due process in ejectment cases. As stated in the decision, “Notwithstanding the actual condition of the title to the property, a person in possession cannot be ejected by force, violence or terror – not even by the owners.” The Court also found that Josefina had indeed established a tenancy relationship with Salvacion, as her father’s successor.

The Court noted, “Upon the death of Sergio Arines in 1997, his daughter Josefina had the right to succeed him to cultivate the land under the same terms of tenancy.” Furthermore, the Court highlighted that “Josefina had been sharing the harvest to Salvacion only that those delivered by her were wet and decayed palay and not dry and clean palay.”

The Supreme Court’s decision reinforced the principle that a tenant’s successor-in-interest is entitled to continue the leasehold relationship, and that any attempt to eject them without due process is illegal.

Practical Implications: Protecting Tenant Rights and Ensuring Due Process

This ruling has significant implications for tenant farmers and landowners alike. It reaffirms the security of tenure for tenants and their successors, ensuring that they cannot be arbitrarily ejected from their landholdings. Landowners must follow due process and file an ejectment case before the PARAD if they wish to terminate a tenancy relationship.

For tenant farmers, this case serves as a reminder of the importance of documenting their tenancy relationship and understanding their rights under RA 3844. They should seek legal assistance if faced with threats of eviction.

Key Lessons:

• Succession in tenancy is protected by law, ensuring continuity for the tenant’s family.
• Illegal ejection from a landholding is not permissible, and tenants must be given due process.
• Tenants should keep records of their lease agreements and payments to prove their tenancy relationship.

Frequently Asked Questions

What is agricultural leasehold?

Agricultural leasehold is a system where tenant farmers have the right to work on agricultural land in exchange for a portion of the harvest, providing them with security of tenure.

Can a tenant be succeeded by a family member after death?

Yes, under RA 3844, a tenant’s successor-in-interest can continue the leasehold relationship, following a specific order of priority among the tenant’s heirs.

What should a tenant do if faced with illegal ejection?

A tenant should seek mediation through local agrarian reform offices and, if necessary, file a complaint with the PARAD for illegal ejectment.

Is it necessary to have a written lease agreement to establish tenancy?

While a written agreement can help prove a tenancy relationship, it is not strictly necessary. Other evidence, such as payments or cultivation records, can also be used.

What are the elements needed to establish a tenancy relationship?

The elements include: the parties are the landowner and tenant, the subject is agricultural land, there is consent, the purpose is agricultural production, there is personal cultivation, and the harvest is shared.

ASG Law specializes in agrarian and agricultural law. Contact us or email hello@asglawpartners.com to schedule a consultation.