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EPITACIO SIALANA v. MARY Y. AVILA SUBSTITUTED BY HER HEIRS

This case has been cited 3 times or more.

2014-10-01
LEONEN, J.
This court has ruled that "[t]enancy is not a purely factual relationship dependent on what the alleged tenant does upon the land [but] is also a legal relationship."[77]  Tenancy relationship cannot be presumed.  The allegation of its existence must be proven by evidence, and working on another's landholding raises no presumption of an agricultural tenancy.[78]  Consequently, the landowner's consent to an agricultural tenancy relationship must be shown.
2009-01-20
PUNO, C.J.
Neither can we give any weight to the petitioners' contention that there was an implied tenancy by reason alone of their continuous cultivation of the land. Acquiescence by the landowner of their cultivation of the land does not create an implied tenancy if the landowners have never considered petitioners Federico and Buenaventura as tenants of the land and if the essential requisites of a tenancy relationship are lacking. There was no intention to institute the petitioners as agricultural tenants. In the case of Epitacio Sialana v. Mary Y. Avila, et al.[71] it was held that "x x x for an implied tenancy to come about, the actuations of the parties taken in their entirety must be demonstrative of an intent to continue a prior lease established by the landholder x x x."[72]
2008-08-28
YNARES-SATIAGO, J.
That respondent was allowed to cultivate the property without opposition, does not mean that the De Leon sisters impliedly recognized the existence of a leasehold relation with respondent. Occupancy and continued possession of the land will not ipso facto make one a de jure tenant.[30] The principal factor in determining whether a tenancy relationship exists is intent. Tenancy is not a purely factual relationship dependent on what the alleged tenant does upon the land but is, moreso, a legal relationship.[31] Thus, the intent of the parties, the understanding when the farmer is installed, and their written agreements, provided these are complied with and are not contrary to law, are more important.[32]