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MANUEL JUSAYAN v. JORGE SOMBILLA

FACTS:

The case involves a dispute over the nature of a lease of agricultural land between the respondent and the predecessor of the petitioners. Wilson Jesena owned four parcels of land in Iloilo and entered into an agreement with respondent Jorge Sombilla, designating Jorge as his agent to supervise the farming of his riceland. Before the agreement expired, Wilson sold the four parcels of land to Timoteo Jusayan. Timoteo and Jorge verbally agreed that Jorge would retain possession of the land and deliver 110 cavans of palay annually to Timoteo without the need for accounting of cultivation expenses. The land was subsequently transferred to Timoteo's sons. In 1984, Timoteo sent letters to Jorge terminating his administration and demanding the return of the land. Timoteo filed a complaint for recovery of possession and accounting against Jorge, which was later substituted by the petitioners following Timoteo's death. The RTC ruled in favor of the petitioners, ordering the delivery of the land. However, the CA reversed the decision, stating that the relationship between the parties was an agricultural tenancy. The petitioners now appeal the decision, questioning the nature of the relationship and the jurisdiction of the RTC.

ISSUES:

  1. Whether the relationship between the parties is that of agency or agricultural leasehold.

  2. Whether the Regional Trial Court had jurisdiction over the case.

RULING:

  1. The Court held that the relationship between the parties was an agricultural leasehold. Therefore, the Regional Trial Court did not have jurisdiction over the case.

PRINCIPLES:

  • In order to determine whether the relationship between parties is that of agency or tenancy, an analysis of the concepts of agency and tenancy must be made.

  • In agency, the agent acts on behalf of the principal, while in tenancy, the land is given to another for the purpose of production through labor.

  • The law does not presume agency, hence, the burden of proving its existence, nature, and extent lies on the person alleging it.

  • The lease of an agricultural land can be either a civil law lease or an agricultural lease. In the civil law lease, the owner gives the use of the land for a certain price and for a definite or indefinite period. In the agricultural lease, the landholder gives possession of the land to another for the purpose of production through labor.