RAFAEL GELOS, vs. THE HONORABLE COURT OF APPEALS and ERNESTO ALZONA.
- G.R. Number: G.R. No. 86186
- Promulgated: 1992-05-08
- Ponente: Cruz, J.
Doctrine
Tenancy is distinguished from a farm employer–farm worker relationship: the former is a lease of land where the tenant's income derives from the produce, while the latter is a lease of labor where the worker receives wages regardless of the employer's profit.
Courts must administer justice to all; sympathy for the poor cannot justify ruling against the landowner when truth and law favor him, though in doubt the poor may be favored.
Facts
Petitioner claims to be a tenant of private respondent and entitled to tenancy-law benefits; respondent contends petitioner was only a hired laborer whose right to occupy ended with employment termination.
The subject is a 25,000 sq. m. farmland in Cabuyao, Laguna originally owned by Ernesto Alzona and his parents in equal shares.
On 5 July 1970 petitioner was employed under a written contract as a laborer at P5.00 daily; on 4 September 1973, after Alzona acquired full ownership, he terminated petitioner's services and demanded possession; petitioner refused and continued working.
Issues
Whether petitioner was a tenant of the subject land entitled to tenancy-law protections or merely a hired laborer whose right to occupy ended with his employment.
Ruling
The Court affirmed the Court of Appeals and denied the petition, ruling against petitioner; costs were awarded against petitioner.
Concurring justices are listed: Narvasa, C.J., Griño-Aquino, Medialdea and Bellosillo, JJ.
Keywords
G.R. No. 86186, tenancy laws, hired laborer, contract of employment, illegal detainer, Court of Agrarian Relations, Ministry of Agrarian Reform, declaration of non-tenancy, Regional Trial Court, Court of Appeals, petition for review under Rule 45 of the Rules of Court, questions of law, factual findings, substantial evidence, Talavera v. Court of Appeals, Kasunduan ng Upahang Araw, lease of services, private, tenant, trial