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    DECENA Case Digest Jugalbot V CA

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    Elias Rafael Decena
    The document discusses a case between the heirs of Jugalbot and Roa regarding a property. Nicolas Jugalbot was issued an Emancipation Patent for a property that was registered under Virginia Roa. The heirs of Roa later filed a complaint seeking cancellation of the title and recovery of possession. The court held that no tenancy relationship existed between Nicolas and Roa since there was no evidence of compensation like lease rentals or a share in produce of the land.

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    DECENA Case Digest Jugalbot V CA

    Uploaded by

    Elias Rafael Decena
    8 views1 page
    The document discusses a case between the heirs of Jugalbot and Roa regarding a property. Nicolas Jugalbot was issued an Emancipation Patent for a property that was registered under Virginia Roa. The heirs of Roa later filed a complaint seeking cancellation of the title and recovery of possession. The court held that no tenancy relationship existed between Nicolas and Roa since there was no evidence of compensation like lease rentals or a share in produce of the land.

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    DECENA Case Digest Jugalbot v CA

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    The document discusses a case between the heirs of Jugalbot and Roa regarding a property. Nicolas Jugalbot was issued an Emancipation Patent for a property that was registered under Virginia Roa. The heirs of Roa later filed a complaint seeking cancellation of the title and recovery of possession. The court held that no tenancy relationship existed between Nicolas and Roa since there was no evidence of compensation like lease rentals or a share in produce of the land.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    8 views1 page

    DECENA Case Digest Jugalbot V CA

    Uploaded by

    Elias Rafael Decena
    The document discusses a case between the heirs of Jugalbot and Roa regarding a property. Nicolas Jugalbot was issued an Emancipation Patent for a property that was registered under Virginia Roa. The heirs of Roa later filed a complaint seeking cancellation of the title and recovery of possession. The court held that no tenancy relationship existed between Nicolas and Roa since there was no evidence of compensation like lease rentals or a share in produce of the land.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    DECENA, Elias Rafael L.

    Arbiter Melchisedek Guan


    L2A, Juris Doctor Agrarian Law and Social Legislation

    HEIRS OF JUGALBOT v CA
    G.R. No. 170346

    Facts:
    On September 28, 1997, an Emancipation Patent (EP) was issued to Nicolas Jugalbot based on the latter’s
    claim that he was the tenant of Lot 2180-C located at Barangay Lapasan, Cagayan de Oro City. The
    subject property was registered in the name of Virginia A. Roa under Transfer Certificate of Title (TCT)
    No. T-11543, the same being issued on April 1, 1970 in the name of "Virginia A. Roa married to Pedro N.
    Roa." Nicolas Jugalbot alleged that he was a tenant of the property continuously since the 1950s. On a
    Certification dated January 8, 1988 and issued by Department of Agrarian Reform (DAR) Team Leader
    Eduardo Maandig, the subject property was declared to be tenanted as of October 21, 1972 and primarily
    devoted to rice and corn.

    On August 10, 1998, the heirs of Roa filed before the DARAB Provincial Office of Misamis Oriental a
    Complaint for Cancellation of Title, Recovery of Possession and Damages against Jugalbot.

    ISSUE/S:
    Whether or not a tenancy relationship exists between the Heirs of Nicolas and Roa

    HELD:
    NO. The fact alone of working on another’s landholding does not raise a presumption of the existence of
    agricultural tenancy. Other factors must be taken into consideration like compensation in the form of
    lease rentals or a share in the produce of the landholding involved. Without the essential elements of
    consent and sharing, no tenancy relationship can exist between the petitioner and the private respondents.

    Bejasa v. Court of Appeals likewise held that to prove sharing of harvests, a receipt or any other evidence
    must be presented as self-serving statements are deemed inadequate. Proof must always be adduced.

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