Cited Laws
TL;DR — Ruling
we affirm the Court of Appeals' ruling that the elements of consent and sharing of harvests are wanting.
Accordingly, their uniform findings bind this Court, as a general rule. Exceptions to this rule exist. III However, even if this case were an exception to the general rule to permit a factual review under Rule 45 of the Rules of Court, we are constrained to affirm the rulings of the lower tribunals. The requisites of a valid agricultural leasehold relationship are settled: For a tenancy relationship, express or implied, to exist, the following requisites must be present: (1) the parties must be landowner and tenant or agricultural lessee; (2) the subject matter is agricultural land; (3) there is consent by the landowner; (4) the purpose is agricultural production; (5) there is personal cultivation by the tenant; and (6) there is sharing of harvests between the landowner and the tenant. [52] (Citation omitted) Each of the elements must be proved by independent and concrete evidence, not mere conjectures or presumptions. [53] Moreover, it is basic that one who alleges must prove their case. [54] In this case, we affirm the Court of Appeals' ruling that the elements of consent and sharing of harvests are wanting. Petitioners failed to prove that they are agricultural lessees. First, petitioners alleged that they were agricultural lessees, but the facts narrated in their Petition consistently show that they were caretakers. They admitted that they were required to inform respondents whenever there was a harvest, but they never discussed any harvest-sharing agreement. [55] Second, a plain reading of the Kasunduan reveals that it contains no stipulation regarding the landowner's consent for the agricultural leasehold relationship and the sharing of harvests between the parties. The material stipulations in the Kasunduan are reproduced below: Pumapayag ang Unang Panig na tumira ang Ikalawang Panig sa Lot 4310, Barangay Ginablan, Romblon, Romblon, na pag-aari ng yumaong si Burgos G. Malaya, nang libre at walang upa; .... Bilang pagtanaw ng utang na loob sa Unang Panig sa kagandahang[]loob at pagpayag na tumira ang Ikalawang Panig sa lupang ito nang libre at walang upa, pumapayag ang Ikalawang Panig na pangalagaan, pagyamanin, at bantayan ang lupang ito. Makapag-aalaga ng "livestock" [manok, baboy, itik, atbp.] ang Ikalawang Panig sa lupang ito, basta't payag ang Unang Panig. Pananatilihin ng Ikalawang Panig na malinis at ligtas ang lupang naturan. Ang anumang anihin ng lupa, maging halaman o "livestock" man ay ipagbibigay-alam ng Ikalawang Panig sa Unang Panig. [56] The Department of Agrarian Reform Adjudication Board correctly held that while petitioners were indeed allowed to cultivate the land, this was only necessary for them to fulfill their obligations under the Kasunduan . [57] It cannot be interpreted as amounting to the landowner's consent to install them as tenants of the property. Indeed, respondents acted at once when they learned that petitioners were cultivating the land and selling the harvest without informing them, in violation of the te
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