Case Digest: NORBERTO RIMASUG et al. v. MELENCIO MARTIN et al.

NORBERTO RIMASUG et al. v. MELENCIO MARTIN et al.

475 SCRA 703 (2005)

Concurrence of all the essential requisites must be established by substantial evidence to prove the existence of a tenancy relationship between the previous landowner and the subsequent landowner.

Petitioners Norberto Rimasug et al. were ―either employees or relatives of some employees‖ who were members of the San Miguel Cooperative Credit Union (SMCCU) organized by the San Miguel Corporation (SMC) labor force. SMCCU acquired several lots and were sold to Rimasug et al. Separate titles were issued in their favor.

Due to financial constraints, Rimasug et al. were unable to construct houses on their respective lots. They later came to know, however, that respondents Melencio Martin et al., without their knowledge and consent, entered the lots on which they planted various agricultural crops. Rimasug et al. thereupon put Martin et al. on notice of their ownership, even bringing the matter before barangay authorities but the latter were ―uncooperative.‖

In the meantime, Rimasug et al. could not ―come up with money to start a legal battle with respondents‖ tolerated Martin‘s et al. continued occupation of their lots until they advised Martin et al. of their intention to build their houses thereon and accordingly asked them to vacate within fifteen (15) days from receipt of the letter. When the demand went unheeded Rimasug et al. filed a complaint for unlawful detainer against them with Municipal Trial Court (MTC).

The MTC held that Martin et al. failed to prove the existence of a landlord-tenant relationship ordering them to vacate the premises. On appeal with the Regional Trial Court (RTC), it affirmed the decision of MTC. Martin et al. filed an Urgent Verified Motion for Immediate Issuance of a Temporary Restraining Order/Writ of Injunction and Petition for Review before the Court of Appeals. The appellate court reversed RTC decision and dismissed the complaint of Rimasug et al.

The appellate court held that, contrary to the findings of both the MTC and the RTC, respondents had satisfactorily proven that they are duly recognized agricultural tenants of SMCCU on the subject lots. And it belied Rimasug et al.’s claim of having tolerated Martin et al.’s occupation of the lots, it charging the former ―as former employees or workers of the previous landowner company‖ with actual knowledge of the latter‘s tenancy.

ISSUE:

Whether or not CA erred in finding that there was an implied tenancy relationship between the Rimasug et al. and Martin et al.

HELD:

For this purpose, the concurrence of all the following essential requisites must be established by substantial evidence: 1.) The parties are the landowner and the tenant or agricultural lessee; 2.) the subject matter of the relationship is an 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 or agricultural lessee; and 6.) the harvest is shared between the landowner and the tenant or agricultural lessee.

By their own admission, Martin et al. were ―informed‖ that the lots they are tilling are ―allegedly‖ owned by SMC because the one collecting the payments was working at SMC, although the official receipts issued to them were under the name of SMCCU. On that score alone, the claim of the existence of a tenancy relationship fails, requirements No. 1 – that the parties are the landowner and the tenant is agricultural lessee, – and No. 3 – that there is consent between the parties – not being present, for how could respondents have contracted with a landowner whose identity they are not even certain of? Such uncertainty becomes more pronounced when note is taken that before the trial and appellate courts they maintained that the lots are owned by SMC.