8. Cuao vs.

CA

The fact that a tenant or an agricultural lessee may have been assisted by farm laborers hired by the landowners,
on occasional or temporary basis, does not preclude the element of "personal cultivation" essential in a tenancy
or agricultural leasehold relationship.
Petition for Review on Certiorari

Petition for Review on Certiorari
Feliciano, J.:
(PAIC omitted, not Agrarian Law relevant)
When Andres Cruz died and left land to his daughters, the tenants continued to work the land and divide the net
proceeds with Carmen and Cecilia. The situation changed when the spouses Amadeo and Aurora Cuao bought
the land from under the tenants noses and ousted them from the premises, preventing any of them from
returning. In response, the tenants commenced a suit against them, arguing that they had the right to redeem the
land as agricultural leasehold lesseesthe trial court agreed with them. The spouses brought the case to the CA,
but the CA agreed with the lower court as well. To the Supreme Court, the spouses now argue:
a) Andres Cruz never consented to the leasehold relationship; tenants were merely paid laborers.
b) There was no personal cultivation by the supposed tenants.
c) (TCT omitted, not relevant to Agrarian Law)
ISSUE and ANSWER:
Petition is bereft of merit.
Elements of Shareholding and Agricultural Leasehold:
1. Partieslandowners and tenants
2. Subjectagricultural land
3. Consentbetween parties
4. Purposeagricultural production
5. Personal Cultivationby tenant
6. Harvestshared by parties

Did Andres Cruz Consent?
Yes. Both Andres Cruz and his two daughters must have known that the overseer could not have cultivated and
cared for the mango plantation and produced the net there from personally and single-handedly nor did they
object to tenant presence or role in the plantation. Knowledge and acquiescence on the part of the landowners
validated the relationship created by the overseer and respondents. The overseer was not an independent
personality who could provide insulation for the landowners.

Did the tenants personally cultivate the land?
Yes. The mere fact that the tenant did not do all the farm work himself but temporarily, or on an emergency
basis, used the services of others to assist him does not mean that the requirements imposed by the statute were
breached since the tenant generally worked the land himself.