Ceneze vs. RamosPetitioner Ceneze fled an action for declaration as bona fde tenant-lessee of twoparcels of agricultural land owned by respondent Feliciana Ramos. He claimed thatthe tenurial rights were transferred to himby him father (former tenant ulian !r."withtheappro#al oftherespondentowner. Respondentdeniedtheclaimstatingthat she (respondent" continued culti#ating the land after the former tenants (ulian$wife$ son - the petitioner"left for the %!.Pro#incial &d'udicator ruled in fa#or of thepetitioner$ asbonafdetenant of thesaidlandholdings. (&Rre#ersed$ andC&sustained the re#ersal.)ssue* +hether or not tenancy relationship still e,ists. Held* Petition deniedRatio*& tenancy relationship cannot be presumed. -here must be e#idence to pro#e thepresence of all its indispensable elements$ to wit* (." the parties are the landownerandthetenant/ (0" thesub'ect isagricultural land/ (1" thereisconsent bythelandowner/ (2" the purpose is agricultural production/ (3" there is personalculti#ation/and(4"thereissharingofthehar#est. -heabsenceofoneelementdoes not ma5e an occupant of a parcel of land$ its culti#ator or planter$ a de 'uretenant.Certifcation issued by the 6&RC Chairman attesting that the former is a tenant ofthelandholdingisnotbindingonthisCourt. -hecertifcationorfndingsofthe!ecretary of&grarian Reform (or ofan authorized representati#e" concerningthepresence or the absence of a tenancy relationship between the contending partiesare merely preliminary or pro#isional in character/ hence$ such certifcation does notbind the 'udiciary.-o pro#e that respondent owner consented to the tenancy relationship$ petitionerpresented an a7da#it e,ecuted by ulian !r (original tenant". Howe#er$ this does notstand because it is not notarized. )t is self-ser#ing and unreliable.-he fact alone of wor5ing on a landholding does not gi#e rise to a presumption ofthee,istenceof agricultural tenancy. !ubstantial e#idencere8uiresmorethanamere scintilla of e#idence in order that the fact of sharing can be established/ theremustbeconcretee#idenceonrecordade8uateenoughtopro#etheelementofsharing. -opro#esharingof har#ests$ areceipt or anyother e#idencemust bepresented$ because self-ser#ing statements are inade8uate. )n this case$ petitionerfailed to present a receipt for respondent9s share in the har#est$ or any other solide#idence pro#ing that there was a sharing of har#est.Petitioner is not a de 'ure tenant entitled to security of tenure.