Sps.

Cayetno vs CA

Facts: Sometime in 1946, the late Severino Manotok donated and transferred to his eight (8)
children and two (2) grandchildren. a thirty-four-hectare lot located in Payong, Old Balara, Quezon
City covered by a certificate of title. Severino Manotok who was appointed judicial guardian of his
minor children 'accepted on their behalf the aforesaid donation. At that time, there were no
tenants or other persons occupying the said property.

In that same year, Teodoro Macaya accompanied by Vicente Herrera, the overseer of the
property, went to the house of Manotok in Manila and pleaded that he be allowed to live on the
Balara property so that he could at the same time guard the property and prevent the entry of
squatters and the theft of the fruits and produce of the fruit trees planted by the owner.
Manotok allowed Macaya to stay in the property as a guard (bantay) but imposed the
conditions that at any time that the owners of the property needed or wanted to take over the
property, Macaya and his family should vacate the property immediately; that while he could
raise animals and plant on the property, he could do so only for his personal needs; that he
alone could plant and raise animals on the property; and that the owners would have no
responsibility or liability for said activities of Macaya. Macaya was allowed to use only three (3)
hectares. These conditions, however, were not put in writing.

The property-owners organized themselves into a corporation engaged primarily in the real
estate business known as the Manotok Realty, Inc. The owners transferred the 34-hectare lot to
the corporation as part of their capital contribution or subscription to the capital stock of the
corporation.

The corporation noted that the realty taxes on the property had increased considerably and
found it very burdensome to pay the said taxes. Macaya upon the request of the owners agreed
to help by remitting ten (10) cavans of palay every year as his contribution for the payment of
the realty taxes beginning 1957.

Eventually, the assessed value of the property had increased thus, the corporation requested
Macaya to increase his contribution from ten (10) cavans to twenty (20) cavans of palay effective
1963.

Macaya informed the corporation that he could not afford anymore to deliver any palay because
the palay dried up.

On January 31, 1974, Manotok Realty, Inc. executed a "Unilateral Deed of Conveyance" of the
property in favor of Patricia Tiongson, Pacita Go, Roberto Laperal III, Elisa Manotok, Rosa
Manotok, Perpetua M. Bocanegra, Filomena M. Sison, Severino Manotok, Jr., Jesus Manotok,
Ignacio S. Manotok, Severino Manotok III and Fausto Manotok.
Manotoks informed Macaya that he needed to vacate the property since they are going to build
their houses thereon. Macaya agreed but pleaded that he be allowed to harvest the palay before
he vacates the property.

However, he did not vacate the property as verbally promised and instead expanded the area he
was working on.

the Manotoks once more told Macaya to vacate the entire property including those portions
tilled by him. At this point, Macaya had increased his area from three (3) hectares to six (6)
hectares without the knowledge and consent of the owners. As he was being compelled to
vacate the property, Macaya brought the matter to the Department (now Ministry) of Agrarian
Reforms.

Macaya to file an action for peaceful possession, injunction, and damages with preliminary
injunction before the Court of Agrarian Relations.

CAR ruled that there was no tenancy relationship. (The Court of Agrarian Relations found that
Macaya is not and has never been a share or leasehold tenant of Severino Manotok nor of his
successors-in-interest over the property or any portion or portions thereof but has only been
hired as a watchman or guard (bantay) over the same.)

IAC ruled otherwise.

Issue: Whether or not there was a tenancy relation in favor of Macaya

Held: No. The Court laid down the essential requisites for a tenancy relationship to exist.: 1) the
parties are the landholder and the tenant; 2) the subject is agricultural land; 3) there is consent;
4) the purpose is agricultural production; and 5) there is consideration.

Real estate taxes of the property declare the land as residential. The physical view of the
property also shows that the land was a rolling forestal land without any flat portion except the
one tilled by Macaya.

As to the sharing, the decision of the petitioners not to ask for anymore contributions from
Macaya reveals that there was no tenancy relationship ever agreed upon by the parties. Neither
can such relationship be implied from the facts as there was no agreed system of sharing the
produce of the property. Moreover, from 1946 to 1956 at which time, Macaya was also planting
rice, there was no payment whatsoever. At the most and during the limited period when it was
in force, the arrangement was a civil lease where the lessee for a fixed price leases the property
while the lessor has no responsibility whatsoever for the problems of production and enters into
no agreement as to the sharing of the costs of fertilizers, irrigation, seedlings, and other items.
As to consent, the lot was taxed as residential land in a metropolitan area. There was clearly no
intention on the part of the owners to devote the property for agricultural production but only
for residential purposes. Thus, together with the third requisite, the fourth requisite which is the
purpose was also not present.