FACTS:

The case involves a dispute between the petitioners and the private respondents regarding the existence of a tenancy relationship under Presidential Decree No. 27. The Court of Appeals reversed the Decision and Resolution of the DARAB Central Office, citing four grounds: absence of tenancy relationship, lack of notice to Virginia Roa, property area, and classification of the property as residential. The Supreme Court reviewed the case upon appeal.

The main issue at hand is whether a tenancy relationship exists between the petitioners and private respondents. The Court established the essential requisites for a tenancy relationship, emphasizing the need for proof rather than presumption. The intent of the parties, understanding upon installation of the farmer, and written agreements are crucial factors in determining the existence of the tenancy relationship.

The petitioners claimed to be bona fide tenants under Presidential Decree No. 27, while the private respondents denied this, raising objections such as lack of notice, residential classification, and separate ownership of the property by Virginia Roa.

The Court concluded that the petitioners are not de jure tenants due to the absence of essential requisites for a tenancy relationship. It also noted that proper notice was not given to Virginia Roa, violating due process. Additionally, the Court clarified that the "married to" phrase on certificates of title does not automatically establish conjugal property, and there was no proof that the property was acquired during the marriage.

Moreover, the defective notice sent to Pedro Roa and the absence of ocular inspection or on-site investigation violated Virginia Roa's right to property and due process. The case of Roxas & Co., Inc. v. Court of Appeals was cited by analogy, emphasizing the importance of strict compliance with legal provisions in the implementation of agrarian reform laws.

The Court highlighted the lack of concrete evidence to prove personal cultivation and sharing of harvests by Nicolas Jugalbot or the petitioners, aside from their self-serving statements. Independent evidence is required to establish a tenancy relationship. Furthermore, despite being a retired US Army soldier residing in California, Jugalbot was certified as the tenant without any on-site investigation, leading to the issuance of an emancipation patent and transfer certificate of title.

ISSUES:

1. Whether or not there was a valid tenancy relationship between the petitioner and the private respondents.

2. Whether or not the subject property is residential or agricultural.

3. Whether the land in question is classified as residential or agricultural.

4. Whether there is a tenancy relationship between the parties.

5. Whether DARAB has jurisdiction over the case.

6. Whether the DARAB committed grave abuse of discretion.

7. The issues in this case are as follows:

8. Whether or not the Transfer Certificate of Title (TCT) No. E-103 issued to Nicolas Jugalbot was valid.

9. Whether or not the Tax Declaration No. 80551 issued to Nicolas Jugalbot was valid.

10. Whether or not the heirs of Nicolas Jugalbot should vacate the premises and turn over its possession to the petitioners, Heirs of Virginia A. Roa.

RULING:

1. No. The court held that the essential elements of consent and sharing were not present, therefore, no tenancy relationship existed between the petitioner and the private respondents.

2. The subject property was classified as residential based on the Zoning Certification No. 98-084 issued by the City Planning and Development Office.

3. The land in question is classified as residential, not agricultural.

4. There is no tenancy relationship between the parties.

5. DARAB does not have jurisdiction over the case.

6. The DARAB committed grave abuse of discretion.

7. The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court ordered the cancellation of TCT No. E-103 and reinstated TCT No. T-11543 in the name of Virginia A. Roa. The Court also directed the cancellation of Tax Declaration No. 80551 issued to Nicolas Jugalbot and the restoration of Tax Declaration No. 270922 in the name of Virginia Angcod Roa. Furthermore, the Court ordered the heirs of Nicolas Jugalbot to vacate the premises and peacefully turn over its possession to the petitioners, Heirs of Virginia A. Roa. No pronouncement as to costs.

PRINCIPLES:

• In order for a tenancy relationship to exist, the elements of consent and sharing must be present.

• The fact of sharing alone is not sufficient to establish a tenancy relationship.

• Self-serving statements regarding tenancy relations are deemed inadequate and proof must always be adduced.

• The source of livelihood of the alleged tenants must be derived from the land they are allegedly tenanting to establish an agricultural tenancy relationship.

• The classification of the property as residential or agricultural is important in determining the nature of the tenancy relationship.

• An agricultural leasehold cannot be established on land that has ceased to be devoted to cultivation or farming due to its conversion into a residential subdivision.

• Land surrounded by a residential zone is always classified as residential.

• The existence of a tenancy relationship must be established before the case can be considered an agrarian dispute falling under the jurisdiction of the DARAB.

• DARAB's jurisdiction is limited to matters involving the implementation of agrarian reform and resolution of agrarian conflicts and land tenure-related problems.

• Laws on social justice favor both the poor and the rich, and do not justify trampling on the rights of the rich in the name of protecting the poor.

• Equal justice under the law is a bedrock principle by which the Republic abides.

• The duty of the court is to protect the less privileged, but not to the extent of denying justice to landowners when truth and justice are on their side.