View full case

RAFAEL GELOS v. CA

FACTS:

The case involves a dispute over the real status of the petitioner, Rafael Gelos, who claims to be a tenant of the private respondent, Ernesto Alzona, and entitled to the benefits of tenancy laws. The subject land is a 25,000 square meter farmland located in Cabuyao, Laguna. Gelos was employed by Alzona and his parents on July 5, 1970, as a laborer on the land at a daily wage of P5.00. Gelos continued working on the land even after Alzona terminated his services on September 4, 1973.

Gelos sought the fixing of the agricultural lease rental on the property at the Court of Agrarian Relations but later withdrew the case and appealed to the Ministry of Agrarian Reform, which granted his petition. Alzona filed a complaint for illegal detainer against Gelos in the Municipal Court of Cabuyao, but it was declared not proper for trial by the Ministry of Agrarian Reform due to the existence of a tenancy relationship. Alzona also sought assistance from the Ministry of Labor and later filed a complaint with the Court of Agrarian Relations for a declaration of non-tenancy and damages against Gelos, but his complaint was declared proper for trial on appeal to the Office of the President.

The Regional Trial Court of San Pablo City rendered a decision stating that Gelos was a tenant of the subject property and entitled to remain thereon. However, the Court of Appeals reversed this decision, holding that Gelos was not a tenant and ordered him to surrender the land to Alzona. The Court of Appeals also awarded attorney's fees and costs to Alzona. Gelos elevated the case to the Supreme Court, arguing that the factual findings of the Court of Appeals were not supported by substantial evidence.

ISSUES:

  1. Whether the agreement between the parties is a tenancy agreement or a contract of employment.

  2. Whether the lack of notarization of the agreement affects its validity.

  3. Whether the tasks specified in the agreement indicate a tenancy relationship.

  4. Whether the petitioner provided evidence of sharing harvest or payment of rentals.

  5. Whether the relationship between the parties is that of tenant and landowner or employer and employee.

  6. Whether or not the payments made by the petitioner were fictitious.

  7. Whether or not the private respondent's complaint for unlawful detainer has prescribed.

RULING:

  1. The agreement between the parties is a contract of employment, not a tenancy agreement.

  2. The lack of notarization does not affect the validity and effectiveness of the agreement.

  3. The tasks specified in the agreement do not indicate a tenancy relationship.

  4. The petitioner failed to provide evidence of sharing harvest or payment of rentals.

  5. The relationship between the parties is that of employer and employee.

  6. The Court held that even if the petitioner claimed that he signed the invoices all at one time because the private respondent allegedly needed them to reduce his income taxes, the payments made were not fictitious because the petitioner never denied having received them.

  7. The Court ruled that the contention that the private respondent's complaint has prescribed under Section 38 of R.A. 3844 is not applicable since there was no tenancy relationship between the parties. The private respondent immediately filed an action for unlawful detainer in accordance with Section 1, Rule 70 of the Rules of Court. The private respondent then resorted to other remedies to recover possession of his land, and finally filed an action for declaration of non-tenancy within the ten-year prescriptive period provided under Article 1144 of the Civil Code for actions based on a written contract.

PRINCIPLES:

  • The intent of the parties and their written agreements determine the relationship between them.

  • The nature of the work involved does not determine the relationship; it is the intention of the parties that matters.

  • A tenant is defined as a person who cultivates the land belonging to or possessed by another, with the latter's consent, for agricultural production, and shares the produce or pays rent to the landowner.

  • An employer-employee relationship is characterized by the selection and engagement of the employee, payment of wages, power of dismissal, and the power to control the employee's conduct.

  • In a farm employer-farm worker relationship, the lease is one of labor with the agricultural laborer as the lessor of his services and the farm employer as the lessee thereof. In a tenancy relationship, the landowner is the lessor, and the tenant is the lessee of agricultural land.

  • The duty of the court to protect the weak and the underprivileged should not be carried out to the extent of denying justice to the landowner whenever truth and justice are on their side.

  • Social justice must be for the deserving, regardless of wealth or poverty. The court must serve justice for both the poor and the rich, according to the mandate of the law.