Loreto Reyes v.

Spouses Honorio and Josefina Joson, Dominador Masangkay and Renato Robles

Facts of the Case:

In 1962, Hilarion Caragay hired Loreto Reyes as caretaker/ watcher of a fishpond and lot 1482 in
Doña Francisca, Balanga, Bataan which he leased from Apolonio Aguire. The contract of lease
between Caragay and Aguire expired in 1973. Later on, Tomas Aguire, son of Apolonio leased
to Honorio Joson the same fishpond until it expires in 1982.

Tomas Aguire appointed Joson as administrator while Loreto Reyes continued to work as
fishpond/watcher. Joson as administrator leased the fishpond to Felizardo Maliboran for five
years. Reyes as bantay palaisdaan signed the contract as witness. Soon enough, same contract of
lease, expired. Joson reverted to the possession of the fishpond.

In November 1989, Caragay, the former lessee, re-entered the fishpond and proceed to harvest
bangus and prawn with the assistance of Reyes. Joson requested Caragay to vacate the premise,
but Caragay refused to that prompted Joson to file forcible entry in MTC Balanga Bataan. They
entered in a compromise agreement approved by the MTC that Caragay and workers will vacate
the property but Caragay failed to comply. MTC issued writ of execution. With this, Reyes filed
TRO in RTC Brach 3, Balanga, Bataan enjoining MTC from implementing the writ.

RTC dismissed the petition for injunction for lack of jurisdiction and conferring upon the DAR
primary jurisdiction to determine and adjudicate Agrarian Reform matters. MTC issued writ of
execution, ejectment of petitioner.

On October 1, 1990, Reyes filed in PARAB-San Fernando, Pampanga complaint for

maintenance of peaceful possession. Reyes alleged that he is agricultural tenant on the fishpond,
entitled to security of tenure and cannot be summarily ejected from property. Additionally, he
invoked that Caragay hired him as fishpond cultivator and he is an industial partner, hence his
share consist of 50% of the harvest. He also raised that when Caragay’s contract of lease expired,
Thomas Aguire hired him as caretaker-industrial partner and that his status for 14 years ripened
into bona fide tenant by operation of law. But Joson, denied the allegations and according to him,
Reyes is a mere fishpond watcher.

On August 18, 1992, PARAB rendered its decision, that Reyes is lawful owner the TRO is
permanent and awarded peaceful possession and actual occupation to Reyes. Joson appealed in
DARAB but of no avail. On November 2, 1996, DARAB affirmed the decision of PARAB and
reinstate back Reyes as tenant-tiller to the fishpond in question immediately without further
delay. The motion for reconsideration of Joson was denied. The case was elevate to CA and
disposed the case saying that DARAB erred in finding that petitioner is an agricultural tenant. On
March 20, 2000, CA granted Joson’s petition, set aside DARAB’s decision and conculsed that
circumstances contradicted by Reyes’ own averments in the complaints he filed with PARAD
but also incompatible with his act of signing the Malibaran lease contract in his capacity as
fishpond watcher and not as tenant.

Hence, this petition to the Supreme Court.

Issue:

Whether or not Reyes is an agricultural tenant and therefore enjoys security of tenure.

Held:

No, Reyes is not and agricultural tenant.

Intent is the principal factor in determining whether a tenancy relationship exists. Tenancy
Relationship is not purely factual relationship but legal relationship.

The requisites to establish tenancy relationship are the following: (1) that the parties are
landowner and tenant and agricultural lessee (2) subject matter of relationship is
agricultural land (3) consent between parties to relationship (4) purpose of relationship is
to bring about agricultural production (5) personal cultivation on the part of the
tenant/agricultural lessee (6) harvest is shared between the landowner and
tenant/agricultural lessee.

Absence of one does not make an occupant of a parcel of land, a de jure tenant, only when
established, he is entitled to security of tenure.

Consent of the landowner to a tenancy arrangement is clearly absent. No proof that Aguirre hired
petitioner as tenant.

Crop sharing is not enough to establish tenancy as it is unusual for the landowner to receive the
production of the land from caretaker who sows.

Mere occupation of an agrarian landowner does not automatically convert a tiller or farm worker
into an agricultural tenant recognized under the agrarian law.

Tenancy status only arises if an occupant has been given possession of an agricultural
landholding for primary purpose of agricultural production.