Association of Small Landowners v DAR SecretaryFacts:These are 3 cases consolidated questioning the constitutionality of the Agrarian ReformProgram. The contention of the petitioners in G.R. No. 7777 is that the pro!ision of RA ""#7 The compensation shall be paid on one of the following modes, at the optionof the landowner: (1) Cash payment,(2) Sharesof stockingovernmentownedor controlledcorporations, !"#preferred shares, physical assets or other $%ali&ed investments inaccordance with g%idelines set by the #'(C) (*) Ta+ credits which can be %sed against any ta+ liability) (,) !"# bondsregarding the modes of payment of $ust compensation is unconstitutional insofar as it requires theo%ners of the e&propriated properties to accept $ust compensation therefor in less than money'%hich is the only mediumof payment allo%ed. RA""#7 allo%s the payment of $ustcompensation (ymeansof )*P *onds' +haresof +toc,singo!ernment-o%ned orcontrolledcorporations' and ta& credits..ssue: /hether or not payment of $ust compensation other than money is allo%ed0eld:.t cannot (e denied that the traditional medium for the payment of $ust compensation ismoney and no other. 0o%e!er' %e do not deal here %ith the traditional e&ercise of the po%er ofeminent domain. This isnot anordinarye&propriation%here onlya specific propertyofrelati!ely limited area is sought to (e ta,en (y the +tate from its o%ner for a specific and perhapslocal purpose. /hat %e deal %ith here is a re!olutionary ,ind of e&propriation. Agrarian Reformprogram %ill in!ol!e not mere millions of pesos. The cost %ill (e tremendous. 1onsidering the!ast areas of land su($ect to e&propriation under the la%s (efore us' %e estimate that hundreds of(illions of pesos %ill (eneeded' far moreindeedthantheamount of P#2(illioninitiallyappropriated' %hich is already staggering as it is (y our present standards. +uch amount is in factnot e!en fully a!aila(le at this time. .t is assumed that the framers of the 1onstitution %ere a%areof this difficulty %hen they called for agrarian reform as a top priority pro$ect of the go!ernment..t is a part of this assumption that %hen they en!isioned the e&propriation that %ould (e needed'they also intended that the $ust compensation %ould ha!e to (e paid not in the orthodo& %ay (uta less con!entional if more practical method.National Housing Authority v AllardeFacts:Pri!ate respondent Rufino 3ateo had li!ed in the disputed lots since his (irth in 1928 .n4#' he started farming and %or,ing on a si&-hectare portion of said lots' after the death of hisfather %ho had culti!ated a thirteen-hectare portion of the same lots. 5n +eptem(er 4' 463' theNational 0ousing Authority notified the respondent spouses of the scheduled develo!ment ofthe "ala #state including the lots in $uestion' %arning them that it %ould not (e responsi(lefor anydamage%hichmay (ecaused to the cropsplanted on thesaidlots..n 46'pri!aterespondent Rufino 3ateo filed %ith the 7epartment of Agrarian Reform a petition for the a%ardto them of su($ect disputed lots under the 1omprehensi!e Agrarian Reform Program 81ARP9. .n:anuary 4;' petitioner caused the (ulldonrique +uplico the agreed "; ca!ans of palay per crop yield. .e+asa v *AFacts:5n+eptem(er ;4' 46=' 1andelaria constitutedrespondent :aime 7inglasanas herattorney-in-fact' ha!ing po%ers of administration o!er the disputed land. 5n 5cto(er ;"' 46='*andelariaentered into a ne% lease contract o!er the land %ith /ictoria Dinglasan' :aime?s%ife %ith a term of one year. 5n 7ecem(er 32' 46=' the *e$asas agreed to pay @ictoria rent ofP4#' 222.22 in consideration of an AaryenduhanA or Apa,ya%na(ungaA agreement' %ith a term ofone year. After the aryenduhan e&pired' despite @ictoria?s demand to !acate the land' the *e$asascontinued to stay on the land and did not give any consideration for its use' (e it in the form ofrent or a shared har!est. 5n Fe(ruary 4#' 466' the *e$asas filed %ith the Regional Trial 1ourt of1alapan' 5riental 3indoro a complaint for confirmation of leasehold and home lot %ith reco!eryof damages against .sa(el 1andelaria and :aime 7inglasan' amd the trial court ruled in fa!ourof the *e$asas. 5n appeal' the *A reversed the decision of the trial court..ssue:/hether or not there is tenancy relationship (et%een the o%ner and the *e$asas0eld:Theelementsofatenancyrelationshipare:849thepartiesarethelando%nerandthetenantB 8;9 the su($ect is agricultural landB 839 there is consentB 8=9 the purpose is agriculturalproductionB 8#9 there is personal culti!ationB and 8"9 there is sharing of har!ests.1andelaria andthe *e$asas' (et%een them' there isno tenancy relationshi!(ut a lease.1andelaria aslando%ner ne!er ga!e her consent. >!en assuming that the 7inglasans had the authority as ci!illa% lessees of the land to (ind it in a tenancy agreement' there is no proof that they did.Almuete v AndresFacts: The su($ect property %as a%arded (y the then National Resettlement and Reha(ilitationAdministration 8NARRA9 to petitioner Rodrigo Almuete. 0e and his family farmed the su($ectpropertypeacefullyande&clusi!elyfor some t%enty-t%o years. 5n August 47' 47' anAgrarian Reform Technologist filed a field in!estigation and inspection report stating that the%herea(outsof Rodrigo Almuete' %asun,no%nandthat hehad%ai!edall hisrightsasaNARRAsettler due to his poor health (eyond his control and financial hardship. Thetechnologist also stated therein that the actual occupant of the land is 3arcelo Andres since April4"7 to date. Thereafter' a homestead patent %as issued in fa!our of Andres. 3arcelo Andresgained control' and too, possession' of appro&imately half of the su($ect property. 1onsequently'Rodrigo Almuete and his daughter' Ana Almuete' filed an action for recon!eyance and reco!eryof possession against 3arcelo Andres %ith the Regional Trial 1ourt of 1auayan' .sa(ela %hichrendered a decision in favour of Almuete. 5n appeal' the 1ourt of Appeals declared the decisionof the trial court NC)) and @5.7 (ecause the case is an agrarian dispute' hence it falls %ithinthe $urisdiction of 7ARA*..ssue:/hether or not the 7ARA* has $urisdiction o!er the case. /ho has a (etter right or theo%ner.0eld:The $urisdiction of the 7ARA* is limited to cases in!ol!ing a tenancy relationship (et%een theparties. Thefollo%ingelementsareindispensa(letoesta(lishatenancyrelationship:849Thepartiesarethelando%ner andthetenant oragricultural lesseeB8;9 Thesu($ect matteroftherelationship is an agricultural landB839 There is consent (et%een the parties to the relationshipB8=9The purpose of the relationship is to (ring a(out agricultural productionB8#9 There is personalculti!ation on the part of the tenant or agricultural lesseeB and8"9 The har!est is shared (et%eenthe lando%ner and the tenant or agricultural lessee. The 1ourt of Appeals gra!ely erred %hen itgranted the petition for certiorari and held that the trial court had no $urisdiction o!er the su($ectmatter of the action (et%een petitioners and respondent since there isno tenancy relationship(et%een them. The action filed (y petitioners %as cogniudosia 7ae&emption of the =.4"6# riceland from co!erage (y P.7. No. ;7 ha!ing(een finally denied her' >udosia7ae< ne&t filed an application for retention of the same riceland'this time under R.A. No. ""#7. The 7AR Regional 7irector allo%ed 7ae< to retain the su($ectland (ut the 7AR +ecretary re!ersed that decision. +he appealed to the 5ffice of the President%hich ruled in her favour. Respondents appealed to the *A which reversed the decision of the5ffice of the President..ssue:/hether or not the denial of application for e&emption under P7 ;7 %ould (ar an application forretention under RA ""#70eld:The requisites for the grant of an a!!lication for e,em!tion from coverage of 8L" andthose for the grant of an a!!lication for the e,ercise of a landowner9s right of retention aredifferent. 0ence' it is incorrect to posit that an application for e&emption and an application forretention are one and the same thing.*eing distinct remedies' finality of $udgment in one doesnot preclude the su(sequent institution of the other. There %as' thus' no procedural impedimentto the application filed (y >udosia7ae< for the retention of the su($ect =.46"#-hectare riceland'e!en after her appeal for e&emption of the same land %as denied in a decision that (ecame finaland e&ecutory.%aris v AlfecheFacts:Petitioner istheregisteredo%ner of t%oparcelsof landsituatedat Paitan' Fue