Guerrero vs. CA - Digest

Sabado
7. Manuel Guerrero and Maria Guerrero v. CA and Apolinario Benitez
DOCTRINE: Cultivation is another important factor in determining the existence of tenancy

relationships. The definition of cultivation is not limited merely to the tilling, plowing or harrowing
of the land. It includes the promotion of growth and the care of the plants or husbanding the
ground to forward the products of the earth by general industry.
FACTS: In 1969, plaintiff Apolinario Benitez was taken by defendants-spouses Manuel and Maria
Guerrero to take care of their 60 heads of cows which were grazing within their 21-hectare coconut
plantation in Aurora, Quezon. Plaintiff was allowed for that purpose to put up a hut within the
plantation where he and his family stayed.
In addition to attending to the cows, he was made to clean the already fruit-bearing coconut trees,
burn dried leaves and grass and to do such other similar chores. During harvest time which usually
comes every three months, he was also made to pick coconuts and gather the fallen ones from a
16-hectare portion of the 21-hectare plantation. He had to husk and split the nuts and then process
its meat into copra in defendants' copra kiln. For his work related to the coconuts, he shared 1/3
of the proceeds from the copra he processed and sold in the market. For attending to the cows,
he was paid P500 a year.
Sometime in the early part of 1973, plaintiff was refrained from gathering nuts from the 10-hectare
portion of the 16-hectare part of the plantation from where he used to gather nuts. He felt
aggrieved by the acts of defendants and he brought the matter to the attention of the Office of
Special Unit in the Office of the President in Malacañang, Manila. This led to an execution of an
agreement whereby defendants agreed, among others, to let plaintiff work on the 16-hectare
portion of the plantation as tenant thereon and that their relationship will be guided by the
provisions of Republic Act No. 1199. The Agricultural Tenancy Act of the Philippines.
Then in July, 1973, he was again refrained from gathering nuts from the 10-hectare portion of the
plantation with threats of bodily harm if he persists to gather fruits therefrom. Defendant spouses,
the Guerreros, then assigned defendants Rogelio and Paulino Latigay to do the gathering of the
nuts and the processing thereof into copra. Defendants Guerreros also caused to be demolished
a part of the cottage where plaintiff and his family lived, thus, making plaintiffs feel that they
(defendants) meant business. Hence, this case for reinstatement with damages.
ISSUE: Whether a tenancy relationship exists between the parties Guerrero and Apolinario
Benitez
RULING: YES. The law denes "agricultural tenancy" as the physical possession by a person of
land devoted to agriculture, belonging to or legally possessed by another for the purpose of
production through the labor of the former and of the members of his immediate farm household
in consideration of which the former agrees to share the harvest with the latter or to pay a price
certain or ascertainable, either in produce or in money, or in both (Section 3, Republic Act 1199.
The Agricultural Tenancy Act, as amended.)
With petitioner reference to this case, "share tenancy" exists whenever two persons agree on a
joint undertaking for agricultural production wherein one party furnishes the land and the other his
labor, with either or both contributing any one or several of the items of production, the tenant
cultivating the land with the aid of labor available from members of his immediate farm household,
and the produce thereof to be divided between the landholder and the tenant in proportion to their
respective contributions (Sec. 4, RA 1199: Sec. 166(25) RA 3844, Agricultural Land Reform
Code).
In contrast, a farmhand or agricultural laborer is any agricultural salary or piece worker but is not
limited to a farmworker of a particular farm employer unless this Code expressly provides
otherwise, and any individual whose work has ceased as a consequence of, or in connection with,
a current agrarian dispute or an unfair labor practice and who has not obtained a substantially
equivalent and regular employment" (Sec. 166 (15) RA 3844, Agricultural Land Reform Code).
In this case, the fact that respondent Benitez, together with his family, handles all phases of farm
work from clearing the landholding to the processing of copra, although at times with the aid of
hired laborers, thereby cultivating the land, shows that he is a tenant, not a mere farm laborer
(delos Reyes v. Espinelli, s u p r a; Marcelo v . de Leon, 105 Phil. 1175).
Further indicating the existence of a tenancy relationship between petitioners and respondent is
their agreement to share the produce or harvest on a "tercio basis" that is, a 1/3 to 2/3 sharing in
favor of the petitioner-landowners. Though not a positive indication of the existence of tenancy
relations per se, the sharing of harvests, taken together with other factors characteristic of tenancy
shown to be present in this case, strengthens the claim of respondent that indeed, he is a tenant.
The petitioners entered into an agreement which in clear and categorical terms establishes
respondent as a tenant, to wit: A G R E E M E N T "This agreement entered into by and between
Manuel Guerrero hereinafter referred to as tenant." . . . The petitioners, however, contend that
the word "tenant" in the aforequoted agreement was used to mean a hired laborer or farm
employee as understood and agreed upon by the parties. The fact that their relationship would
be guided by the provisions of Republic Act 1199 or the Agricultural Tenancy Act of the Philippines
militates against such an assertion. It would be an absurdity for Republic Act 1199 to govern an
employer-employee relationship. If as the petitioners insist a meaning other than its general
acceptation had been given the word "tenant", the instrument should have so stated. Aided by a
lawyer, the petitioners, nor the respondent could not be said to have misconstrued the same.
Therefore, in clear and categorical terms, the private respondent appears to be nothing else but
a tenant.
DISPOSITIVE: WHEREFORE, the petition is DISMISSED for lack of merit. The decision of the
appellate court is AFFIRMED.

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Sabado

7. Manuel Guerrero and Maria Guerrero v. CA and Apolinario Benitez

DOCTRINE: Cultivation is another important factor in determining the existence of tenancy

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