View full case

REYNALDO BEJASA v. CA

FACTS:

The case involves two parcels of land owned by Isabel Candelaria, located in Barangay Del Pilar, Naujan, Oriental Mindoro. In 1974, Candelaria entered into a three-year lease agreement with Pio Malabanan, who agreed to cultivate and care for the land. Malabanan hired the petitioners, Reynaldo and Erlinda Bejasa, to plant citrus, calamansi, rambutan, and banana trees on the land. In 1977, Candelaria gave Malabanan a six-year usufruct over the land. After Malabanan's death, Candelaria appointed Jaime Dinglasan as her attorney-in-fact in 1984 and entered into a new lease contract with Victoria Dinglasan, Jaime's wife. The Bejasas agreed to pay Victoria rent for the land, but they failed to fully settle the payment. Despite the expiration of the lease, the Bejasas continued to occupy the land without offering rent or a shared harvest. In 1987, Candelaria and the Dinglasans entered into another lease agreement and Jaime filed a complaint for the Bejasas' ejectment before the COSLAP, which was later dismissed. Jaime then filed a complaint for recovery of possession with the trial court, but the case was referred to the DAR. The DAR certified that the case was not proper for trial before the civil courts. The trial court dismissed Jaime's complaint, and the Bejasas filed their own complaint for confirmation of leasehold and home lot with recovery of damages in 1988. The trial court ruled in favor of the Bejasas, recognizing their tenancy relationship and security of tenure.

ISSUES:

  1. Whether or not the Bejasas are tenants of the disputed landholdings.

RULING:

  1. The Court of Appeals reversed the decision of the trial court, finding that the Bejasas are not tenants and ordering them to surrender the possession of the land to Candelaria. The Court of Appeals ruled that the Bejasas failed to establish the existence of a tenancy relationship and that they were merely workers or laborers for Malabanan.

PRINCIPLES:

  • Whether a person is a tenant is a factual question.

  • To establish a tenancy relationship, there must be a person who furnishes the landholding as owner, civil law lessee, usufructuary, or legal possessor, and a person who personally cultivates the land.

  • A tenancy relationship grants the tenant security of tenure.