Understanding Abandonment in Agrarian Leasehold: Tenant’s Rights Protected

G.R. No. 257980 (Formerly UDK-16986), June 26, 2024

Imagine a farmer, tilling the same land for generations, suddenly facing eviction. Can a temporary agreement to let someone else manage the land lead to the loss of their livelihood? This is the core issue addressed in the Supreme Court case of Rodolfo A. Dela Cruz and Celerino A. Dela Cruz vs. Jesusa Y. Cailles. The case revolves around the concept of abandonment in agrarian law and how it affects the rights of agricultural lessees. The Supreme Court ultimately sided with the farmers, emphasizing the high burden of proof required to demonstrate abandonment and safeguarding the rights of tenants.

Agrarian Leasehold and the Concept of Abandonment

Agrarian reform in the Philippines aims to promote social justice and provide farmers with security of tenure. Republic Act No. 3844, also known as the Agricultural Land Reform Code, governs the relationship between landowners and agricultural lessees. A key provision is Section 8, which outlines the circumstances under which an agricultural leasehold relation can be extinguished. One of these circumstances is “Abandonment of the landholding without the knowledge of the agricultural lessor.”

Abandonment, in this context, isn’t just about physically leaving the land. It requires a clear and deliberate intention to give up all rights and interests in the property. The Supreme Court has consistently held that proving abandonment requires demonstrating:

1. A clear and absolute intention to renounce a right or claim.
2. An external act by which that intention is expressed or carried into effect.

The intention to abandon must be unequivocal, implying a departure with the intent of never returning. Furthermore, this intent must be demonstrated by a factual failure or refusal to work on the landholding without a valid reason for a significant period, generally considered to be at least two calendar years.

Hypothetical Example: Suppose a farmer, facing temporary financial hardship, enters into an agreement with a neighbor to cultivate their land for one season. The farmer continues to live nearby, occasionally assists with the work, and expresses a clear intention to resume full cultivation the following season. In this scenario, abandonment would likely not be established, as the farmer’s intent to return is evident.

It’s also important to note that a notarized document, like the Sinumpaang Salaysay (Voluntary Surrender) in this case, carries significant weight. However, the Court also considers the totality of the circumstances and the actual conduct of the parties involved.

The Dela Cruz vs. Cailles Case: A Detailed Look

The case began when Jesusa Y. Cailles, represented by Alicia Y. Yacat, filed a complaint seeking to evict Rodolfo and Celerino Dela Cruz (the Dela Cruzes) from a parcel of land they had been farming. Cailles argued that the Dela Cruzes had abandoned the land by executing a Sinumpaang Salaysay in favor of Carlito Adel, allowing him to possess and cultivate a portion of the land.

The Dela Cruzes countered that they were misled into signing the document, believing it was related to a loan transaction with Adel. They maintained that they never intended to abandon the land and continued to cultivate it. The case proceeded through several levels of adjudication:

• Provincial Agrarian Reform Adjudication Board (PARAD): Initially ruled in favor of Cailles, declaring the leasehold relationship severed based on the Sinumpaang Salaysay.
• Department of Agrarian Reform Adjudication Board (DARAB): Reversed the PARAD’s decision, finding no valid cause to terminate the leasehold. The DARAB emphasized that the Dela Cruzes continued to cultivate the land and pay lease rentals.
• Court of Appeals (CA): Reversed the DARAB’s ruling and reinstated the PARAD’s decision, giving significant weight to the notarized Sinumpaang Salaysay.
• Supreme Court: Overturned the CA’s decision, siding with the Dela Cruzes and upholding the DARAB’s finding that there was no abandonment.

The Supreme Court, in its decision penned by Justice Kho, Jr., emphasized that while the Sinumpaang Salaysay was a notarized document entitled to full faith and credit, the totality of the circumstances did not support a finding of abandonment. The Court quoted the crucial element to prove abandonment:

“[I]t is incumbent to prove the following: (a) a clear and absolute intention to renounce a right or claim or to desert a right or property; and (b) an external act by which that intention is expressed or carried into effect.”

The Court also highlighted the fact that the Dela Cruzes continued to pay lease rentals, which were accepted by Cailles’ representatives. As the court stated:

“[T]he receipt of lease rentals from Carlito and Sabrina effectively estopped Yacat from denying prior knowledge and consent to the transaction between the Dela Cruzes and Carlito, and Cailles is deemed to have consented to the loan transaction, and ratified the construction of the house by accepting lease rentals from the Dela Cruzes through Yacat.”

Furthermore, the court considered the fact that Carlito Adel returned the land to the Dela Cruzes’ control less than two years after the execution of the Sinumpaang Salaysay, negating any claim of prolonged relinquishment of possession.

Practical Implications and Lessons Learned

This case serves as a crucial reminder of the importance of protecting the rights of agricultural lessees. Landowners must demonstrate a clear and unequivocal intention to abandon the land, supported by concrete evidence, before a leasehold relationship can be terminated.

Key Lessons:

• A notarized document alone is not sufficient to prove abandonment; the surrounding circumstances and the conduct of the parties must be considered.
• Acceptance of lease rentals after an alleged act of abandonment can be construed as a waiver of the right to terminate the leasehold.
• The burden of proof lies on the landowner to demonstrate a clear and deliberate intent to abandon the land, coupled with a prolonged period of non-cultivation.

Advice: Agricultural lessees should meticulously document all payments of lease rentals and any interactions with the landowner or their representatives. Any agreements regarding temporary transfer of land management should be carefully drafted and clearly state the intention to resume full cultivation in the future.

Frequently Asked Questions (FAQs)

Q: What constitutes abandonment of agricultural land?

A: Abandonment requires a clear intention to give up all rights to the land, coupled with a prolonged period (at least two years) of non-cultivation without a valid reason.

Q: Can a temporary agreement to let someone else cultivate my land be considered abandonment?

A: Not necessarily. If you clearly express your intention to resume cultivation in the future and continue to exercise some control over the land, it may not be considered abandonment.

Q: What evidence is needed to prove abandonment?

A: Evidence may include a written declaration of intent to abandon, prolonged absence from the land, failure to cultivate the land for an extended period, and failure to pay lease rentals.

Q: What should I do if my landlord claims I have abandoned my land?

A: Gather all evidence that supports your claim that you have not abandoned the land, such as receipts for lease payments, affidavits from neighbors, and any documents related to your cultivation of the land. Consult with a lawyer specializing in agrarian law.

Q: Does a notarized document automatically prove abandonment?

A: No. While a notarized document carries weight, the court will consider all surrounding circumstances and the conduct of the parties to determine whether abandonment has occurred.

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