GELOS VS. CA
Agricultural
It is not the nature of the work involved but the
intention of the parties that determine the
relationship between them. Tenancy is not a
purely factual relationship dependent upon
what the alleged tenant does it is also a legal
relationship.
TEODORO VS MACARAEG
Title, label or rubric given to a contract cannot be
used to camouflage the real import of an
agreement as evinced by its main provisions. A
contract Is what the law defines it to be not what
it is called.
The tenant-lessees security of tenure subsists
notwithstanding the termination of the contract
which initially established the tenancy relation.
ZAMORA VS. SO
Essential requisites for an agricultural leasehold:
1) landowner and tenant relationship 2)
agricultural landholding 3) consent of landowner
4) for agricultural production 5) personal
cultivation 6) sharing of harvest. Absent the
personal cultivation of the tenant, So is merely
an employee.
CASTILLO VS. CA
The fact that the source of livelihood is not
derived from the lot they are allegedly tenanting
is indicative of non-agricultural tenancy
relationship. All requisites must concur in order
to create a tenancy relationship between the
parties. Unless a person has established his
status as a de jure tenant, he is not entitled to
security of tenure nor is he covered by the Land
Reform Program
BERNAS VS. CA
Benigno was the legal possessor of the property
by virtue of the usufruct agreement between
him and the landowner, thus he has authority
and capacity to enter into an agricultural
leasehold relation with Bernas.
leasehold relationship existed by operation of
law when there is concurrence of lessor and
lessee. The grounds for ejectment provided by
law are exclusive
TANPINGCO VS IAC
Leasehold relation not extinguished by donation
or transfer.
CABALLES VS DAR
An economic family sized farm is an area of farm
land that permits efficient use of labor and
capital resources of the family farm and will
produce an income sufficient to provide a
modest standard of living to meet farm familys
needs. The area is only 60 sq.m., it is not an
economic family sized farm.
Absence of one of the essential requisites does
not make the occupant a de jure tenant. In this
case, Abajon is merely a caretaker since
agricultural production is absent.
ENDAYA VS. CA
Transactions involving the land resulting in
change of ownership such as lease will not
terminate the right of the agricultural lessee
HILLARIO VS IAC
Landholder has the right to initially choose his
tenant to work on his land. Cultivation by
usurper cannot confer upon him any legal right
to work as tenant. Agricultural tenancy is a legal
relationship.
A lot inside a poblacion should be presumed
residential or commercial or non-agricultural
unless there is a clearly preponderant evidence
to show that it is agricultural.
GABRIEL VS PANGILINAN
LEASEHOLD CIVIL LAW LEASE
TENANCY
Agricultural land Rural or urban
 Personal cultivation Need not personally
cultivate
Purpose: agriculture Can engage in any
other lawful pursuits
Special law Civil code
Security of tenure
PRIMERO VS CAR
Once tenancy relationship is established, the
tenant is entitled to security of tenure with right
to continue working on and cultivating the land
until he is dispossessed.
It is constitutional because it does not impair the
right of landowner to dispose or alienate his
property nor prohibit him to make such transfer
or alienation. The purpose is only to maintain the
tenant in the peaceful possession and cultivation
of the land.
ALITA VS CA
Under Sec 6, Art XIII of the 1987 Constitution,
agrarian reform is subject to prior rights,
homestead rights and rights if indigenous people
to their ancestral lands. Also in sec 6 RA6657
(CARP law), original homestead grantees who
still own the original homestead shall retain the
same as long as they continue to cultivate said
homestead.
CENTRAL MINDANAO UNIVERSITY VS DARAB
400ha was alleged not directly, actually and
exclusively used for school site since it was
leased to Phil Packaging Corp. CMU is in the best
position to resolve the problem of its need in
relation to its objectives. Neither DARAB nor the
court has right to substitute its judgement unless
evidentiary facts are so manifest to show that
CMU has no real need for the land.
DARABs quasi-judicial powers does not include
authority to make an award beyond what was
demanded by the complainants. Going beyond
what was demanded constitutes grave abuse of
discretion.
CASTRO VS CA
When parties have reduced their agreements to
writing, they are presumed to have intended the
writing as the only evidence of their agreement
and thus supposed to have embodied therein all
the terms of their agreement. A contract cannot
be invalidated to create tenancy relationship by
mere fact that plaintiffs now seek to disown said
contract on blind belief of claim of actual
tenancy or on mere allegations devoid of actual
positive proof. Contract is the law between the
parties.
DAVAO STEEL VS. CABATUANDO
At the time of purchase, the land is agricultural.
It did not become industrial just because the
corporation intended it to be so. The
Corporation cannot disclaim knowledge when
reasonable inquiry would have disclose that it is
tenanted. In a tenanted land, owner cannot
unilaterally convert without consent of tenant
because tenant enjoys security of tenure.
DE BORJA VS CA
PD27 cannot be applied retroactively
EVANGELISTA VS CA
The salient characteristic that will make the
relationship an agricultural leasehold, ie.
personal cultivation, is absent since petitioner
hire many laborers and is a rice dealer.
Furthermore, there is intent to establish a civil
lease contract since the contract was signed for
3 consecutive times.
LACUESTA VS BRGY CASABAAN
Under security of tenure, the tenant is entitled
to protection even where eminent domain is
exercised. Thus, he is entitled to compensation
where tenanted landholding is expropriated.
LASTIMOZA VS BLANCO
Tenancy relationship can only be created with
consent of true and lawful landholder who is
either the owner, lessee, usufructuary, or legal
possessor of the land. A tenant of an usurper or
intruder has no better right. Security of tenure is
for de jure tenants only.
LOCSIN VS VALENZUELA
Under PD27, lease rentals paid will be credited
as amortization payments. PD27 effectively
extinguished the usufructuary on the land even
if it is lifetime. Otherwise, it would defeat
purpose of land reform.
Art 609 applies by analogy to a person with a
lifetime usufructuary. He is entitled to
replacement of a reasonably equivalent to the
land previously burdened by her usufructuary
right.
LUZ FARMS VS DAR
Ra6657 includes raising of livestock, poultry and
swine in coverage. It is never the intention of the
framers of the Constitution to include livestock
and poultry industry in the word agricultural
under agricultural reform program. Agricultural
land is limited to arable and suitable agricultural
land and therefore do not include commercial,
industrial or residential.
MATIENZO VS SERVIDAD
When in doubt in interpretation of a contract, its
literal meaning shall control and the entirety of
the contract must be taken into consideration.
Absent a sharing agreement, no tenancy
relationship exist.
MILESTONE FARM VS OFFICE OF THE PRESIDENT
Property should remain livestock farm in order
to be exempted form coverage. Furthermore, it
should be actually, directly and exclusively use
landholding for such purpose
NATALIA VS DAR
Coverage of RA6657 is all public and private
agricultural lands. Land not devoted for
agricultural activity is outside the coverage of
CARP. It includes land converted prior to
effectivity of CARP even if it is an undeveloped
portion of a subdivision that had long before
been converted to residential.
PADASAS VS CA
RA3844 must be applied prospectively. The 2
year period of redemption must be counted
from date of registration of sale. Sale
contemplated in RA3844 is consummated not a
conditional sale.
PAGTALUNAN VS TAMAYO
The Certificate of land transfer under PD27 does
not vest farmer/grantee ownership. It is only a
recognition that grantee is qualified to avail.
Prior to compliance with the terms and
conditions, he merely possess a contingent or
expectant right.
PROV OF CAM SUR VS CA
Requirement in RA6657 that before land can be
reclassified it requires approval of DAR applies to
land previously placed under agrarian reform
program. The power of eminent domain is
superior.
SMALL LANDOWNERS VS SEC OF DAR
PD27, proclamation 131, EO229 was made
during Martial law or during the time when there
is no congress. There is no violation of separation
of powers. Furthermore, Congress enacted
RA6657 thereafter.
The just compensation to be determined by DAR
is not final and conclusive. It should still be
brought to court for final determination.
Agrarian reform program is not an ordinary
expropriation. It affects all private agricultural
lands and covers the whole territory of the
Philippines. The cost would be tremendous and
thus just compensation in cash is not a practical
method.

VINZONS-MAGANA VS ESTRELLA

LOI474 was made pursuant to PD27. It does not

deprive a person of due process or without just
compensation.

Mere issuance of Certificate of Land Transfer do

not vest ownership. It is only an evidence of
governments recognition of the grantee as a
party qualified under PD27. It only gives an
expected or contingent right. IT is the
Emancipation Patent that gives a vested right of
absolute ownership.

ZURBANO VS ESTRELLA

LOI 474 is constitutional because it is

Constitution itself who decreed Agricultural land
reform Program. There is no deprivation of due
process since due regard was given to
landholders (given the chance to present
evidence on true value of land) The exception is
only if in other lands owned, the owner is unable
to derive income adequate to support
themselves.

SANTOS VS VDA DE CERDENOLA

By the contract of marriage, a man and woman

entered into joint life and becomes a single
moral, spiritual and social being. The wife of a
dead tenant becomes the tenant by implication
when she in her own right, is allowed to cultivate
the farm for several years.