Castillo vs.

CA
205 SCRA 529 (1992)
Facts:
Alberto Ignacio filed a complaint for injunction against Castillo alleging that he is the agricultural
tenant of the latter. He claims that Castillo allowed him to construct a rest house in the property
and that, thereafter, Castillo started cutting fruit-bearing trees on the land and filled with adobe
stones the area intended for vegetables. On the other hand, Castillo denied that Ignacio was his
tenant but that the latter was only a "magsisiga" of the landholding and that he did not ask
permission from Ignacio when he constructed his rest house. The trial court found no tenancy
relationship between the parties but this was reversed by the Court of Appeals.
Held:
The element of personal cultivation is absent in this case. The alleged tenant "is a businessman
by occupation and this is his principal source of income. He manufactures hollow blocks. He also
has a piggery and poultry farm as well as a hardware store on the land adjoining the subject
land. To add to that, the respondent farms the riceland of one Dr. Luis Santos. It is thus evident
that the working hours of the respondent as a businessman and his other activities do not permit
him to undertake the work and obligations of a real tenant. This is further supported by the
undisputed fact that the respondent cannot even personally perform the work of a smudger
because on 22 October 1986, the respondent hired some 20 people who are not members of his
family to cut and burn the grass in the premises of the subject land." (at 535-536).
An owner tilling his own agricultural land is not a tenant within the contemplation of the law
(Baranda vs. Baguio, 189 SCRA 194 (1990).
In Oarde vs. CA, et al., 280 SCRA 235 (1997), certifications of tenancy/non-tenancy issued by
DAR are not conclusive.
"The certifications issued by administrative agencies or officers that a certain person is a tenant
are merely provisional and not conclusive on courts, as ruled by this Court in Cuao vs. Court of
Appeals, citing Puertollano vs. IAC. Secondly, it is well-settled that the "findings of or
certifications issued by the Secretary of Agrarian Reform, or his authorized representative, in a
given locality concerning the presence or absence of a tenancy relationship between the
contending parties is merely preliminary or provisional and is not binding upon the courts." (at
246)
Landholder-lessor
A landholder-lessor is defined as "any person, natural or juridical, either as owner, lessee,
usufructuary or legal possessor of agricultural land, who lets, leases or rents to another said
property for purposes of agricultural production and for a price certain or ascertainable either in
an amount of money or produce." (Rep. Act No. 1199 [1954], sec. 42). Thus, consent need not be
necessarily given personally by the registered owner as long as the person giving the consent is
the lawful landholder as defined by law.