"x x x.
The Court may resolve questions of fact only in exceptional cases,[21]which is not present here. The Court upholds the finding of the Court of Appeals that petitioner failed to present any evidence to show that a tenancy relationship existed between petitioner and respondents Spouses Pitcock. Jeremias v. Estate of the late Irene P. Mariano[22] held:
Claims that one is a tenant do not automatically give rise to security of tenure. The elements of tenancy must first be proved in order to entitle the claimant to a security of tenure.
A tenant has been defined under Section 5 (a) of Republic Act No. 1199, otherwise known as the Agricultural Tenancy Act of the Philippines, as a person, who, himself, and with the aid available from within his immediate farm household, cultivates the land belonging to or possessed by another, with the latter’s consent for purposes of production, sharing the produce with the landholder, under the share tenancy system, or paying to the landholder a price certain or ascertainable in produce or in money or both, under the leasehold system.
This Court had once ruled that self-serving statements regarding tenancy relations could not establish the claimed relationship. The fact alone of working on another’s landholding does not raise a presumption of the existence of agricultural tenancy. Substantial evidence entails not only the presence of a mere scintilla of evidence in order that the fact of sharing can be established; there must also be concrete evidence on record that is adequate to prove the element of sharing. In fact, this Court likewise ruled that to prove sharing of harvests, a receipt or any other evidence must be presented; self-serving statements are deemed inadequate.[23]
x x x."
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