This case has been cited 4 times or more.
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2015-01-21 |
BERSAMIN, J. |
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| It is elementary that he who alleges the affirmative of the issue has the burden of proof.[29] Hence, Jorge, as the one claiming to be an agricultural tenant, had to prove all the requisites of his agricultural tenancy by substantial evidence.[30] In that regard, his knowledge of and familiarity with the landholding, its production and the instances when the landholding was struck by drought definitely established that he personally cultivated the land.[31] His ability to farm the seven hectares of land despite his regular employment as an Agricultural Technician at the Municipal Agriculture Office[32] was not physically impossible for him to accomplish considering that his daughter, a member of his immediate farm household, was cultivating one of the parcels of the land.[33] Indeed, the law did not prohibit him as the agricultural lessee who generally worked the land himself or with the aid of member of his immediate household from availing himself occasionally or temporarily of the help of others in specific jobs.[34] In short, the claim of the petitioners that the employment of Jorge as an Agricultural Technician at the Municipal Agriculture Office disqualified him as a tenant lacked factual or legal basis. | |||||
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2014-10-01 |
LEONEN, J. |
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| There must be substantial evidence on the presence of all these requisites; otherwise, there is no de jure tenant.[40] Only those who have established de jure tenant status are entitled to security of tenure and coverage under tenancy laws.[41] | |||||
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2011-06-08 |
DEL CASTILLO, J. |
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| As we have often said, mere occupation or cultivation of an agricultural land will not ipso facto make the tiller an agricultural tenant.[47] It is incumbent upon a person who claims to be an agricultural tenant to prove by substantial evidence all the requisites of agricultural tenancy.[48] | |||||
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2009-06-16 |
NACHURA, J. |
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| Petitioners' assertion that they were allowed to cultivate the subject property without opposition, does not mean that PASUDECO impliedly recognized the existence of a leasehold relation. Occupancy and continued possession of the land will not ipso facto make one a de jure tenant, because the principal factor in determining whether a tenancy relationship exists is intent.[53] This much we said in VHJ Construction and Development Corporation v. Court of Appeals,[54] where we held that: Indeed, a tenancy relationship cannot be presumed. There must be evidence to prove this allegation. 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. It is also a legal relationship. As we ruled in Chico v. Court of Appeals[347 SCRA 35 (2000)]: | |||||