June 1962 - Philippine Supreme Court Decisions/Resolutions
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G.R. No. L-18431 June 30, 1962 - RUFINO ALARCON, ET AL. v. PILAR SANTOS, ET AL. :
EN BANC
[G.R. No. L-18431. June 30, 1962.]
RUFINO ALARCON, ET AL., Petitioners, v. PILAR SANTOS, ET AL., Respondents.
Gaudencio M. Balingit, for Petitioners.
Eufrocino L. Bermudez for Respondents.
SYLLABUS
1. TENANCY; EXPIRATION OF TENANCY CONTRACT DOES NOT TERMINATE OUTRIGHT RELATIONSHIP; ACTION FOR REINSTATEMENT OF TENANT UNDER JURISDICTION OF AGRARIAN COURT. — Pursuant to Section 9 of Republic Act No. 1199, even if there is a contract creating a leasehold or tenancy relationship, the mere expiration of the period of the contract does not terminate outright the relationship between the parties, because the law imposes upon the new landholder or owner the duty to assume all the rights and obligations of the former landholder with the particularity that if the latter dies his heirs shall likewise assume the same right and obligations. Should this eventuality happen, if the owner or transferee dispossess the tenants of the land, the remedy of the latter is to seek reinstatement with damages in the Court of Agrarian Relations which shall have exclusive jurisdiction thereof.
D E C I S I O N
BAUTISTA ANGELO, J.:
On March 28, 1960, Rufino Alarcon, Et Al., filed a petition for reinstatement and damages against Pilar Santos before the Court of Agrarian Relations of Pangasinan. It is alleged that the land they were working on as tenants belong to Pilar Santos but was leased to one Dionisio Alarcon who employed them as tenants but that after the contract of lease was terminated, thru trickery and stealth, they were forcibly ejected by Pilar Santos.
Pilar Santos denied the main averments of the petition setting up as a defense that as a owner of the land she is entitled to exercise all rights that pertain to her ownership. She asks that she be awarded damages in the amount of P200.00.
After trial, the agrarian court found that the land in controversy was owned by Pilar Santos but leased to Dionisio Alarcon who employed petitioners as tenants, and since Dionisio Alarcon was not made party respondent, it concluded that there is no tenancy relationship existing between petitioners and Pilar Santos. As a consequence, it dismissed the petitioner for want of jurisdiction.
Petitioners interposed the present appeal for review.
In dismissing the petition for want of jurisdiction, the agrarian court made the following comment: "It is apparent . . . that Dionisio Alarcon is not one of the respondents who should be the principal one because he is alleged to be the landholder of the respondents. Although according to the petitioners Mrs. Pilar Santos is the owner she is not the landholder because it was admitted by the petitioners that Dionisio Alarcon is their landholder being the lessee of the property. No evidence was presented about the tie-up or relationship between Pilar Santos and the petitioners. The Court can only take cognizance of cases brought to it between landholders and tenants."cralaw virtua1aw library
With this comment we disagree, as it is an open infringement of the letter and spirit of Section 9 of Republic Act No. 1199, which we quote:jgc:chanrobles.com.ph
"SEC. 9 Severance of Relationship. — The tenancy relationship is extinguished by the voluntary surrender of the land by, or the death or incapacity of, the tenant, but his heirs or the members of his immediate farm household may continue to work the land until the close of the agricultural year. The expiration of the period of the contract as fixed by the parties, and the sale or alienation of the land do not of themselves extinguish the relationship. In the latter case, the purchaser or transferee shall assume the rights and obligations of the former landholder in relation to the tenant. In case of death of the landholders, his heir or heirs shall likewise assume his rights and obligation."cralaw virtua1aw library
Note that even if there is a contract creating a leasehold or tenancy relationship between the owner of the land and a tenant, the mere expiration of the period of the contract does not terminate outright the relationship between the parties, because the law imposes upon the new landholder or owner the duty to assume all the rights and obligations of the former landholder with the particularity that if the latter dies, his heirs shall likewise assume the same rights and obligations. Should this eventuality happen, if the owner or transferee dispossess the tenants of the land, the remedy of the latter is to seek reinstatement with damages. Such is the action taken by petitioners. This incident comes within the exclusive jurisdiction of the Court of Agrarian Relations. 1
WHEREFORE, the resolution of the agrarian court dated March 23, 1961, as well as its order denying petitioners’ motion for reconsideration dated April 11, 1961, are hereby set aside. The case is remanded to the agrarian court for further proceedings. Costs against Pilar Santos.
Bengzon, C.J., Padilla, Labrador, Concepcion, Barrera, Paredes, Dizon, Regala and Makalintal, JJ., concur.
Reyes, J.B.L., J., took no part.
Pilar Santos denied the main averments of the petition setting up as a defense that as a owner of the land she is entitled to exercise all rights that pertain to her ownership. She asks that she be awarded damages in the amount of P200.00.
After trial, the agrarian court found that the land in controversy was owned by Pilar Santos but leased to Dionisio Alarcon who employed petitioners as tenants, and since Dionisio Alarcon was not made party respondent, it concluded that there is no tenancy relationship existing between petitioners and Pilar Santos. As a consequence, it dismissed the petitioner for want of jurisdiction.
Petitioners interposed the present appeal for review.
In dismissing the petition for want of jurisdiction, the agrarian court made the following comment: "It is apparent . . . that Dionisio Alarcon is not one of the respondents who should be the principal one because he is alleged to be the landholder of the respondents. Although according to the petitioners Mrs. Pilar Santos is the owner she is not the landholder because it was admitted by the petitioners that Dionisio Alarcon is their landholder being the lessee of the property. No evidence was presented about the tie-up or relationship between Pilar Santos and the petitioners. The Court can only take cognizance of cases brought to it between landholders and tenants."cralaw virtua1aw library
With this comment we disagree, as it is an open infringement of the letter and spirit of Section 9 of Republic Act No. 1199, which we quote:jgc:chanrobles.com.ph
"SEC. 9 Severance of Relationship. — The tenancy relationship is extinguished by the voluntary surrender of the land by, or the death or incapacity of, the tenant, but his heirs or the members of his immediate farm household may continue to work the land until the close of the agricultural year. The expiration of the period of the contract as fixed by the parties, and the sale or alienation of the land do not of themselves extinguish the relationship. In the latter case, the purchaser or transferee shall assume the rights and obligations of the former landholder in relation to the tenant. In case of death of the landholders, his heir or heirs shall likewise assume his rights and obligation."cralaw virtua1aw library
Note that even if there is a contract creating a leasehold or tenancy relationship between the owner of the land and a tenant, the mere expiration of the period of the contract does not terminate outright the relationship between the parties, because the law imposes upon the new landholder or owner the duty to assume all the rights and obligations of the former landholder with the particularity that if the latter dies, his heirs shall likewise assume the same rights and obligations. Should this eventuality happen, if the owner or transferee dispossess the tenants of the land, the remedy of the latter is to seek reinstatement with damages. Such is the action taken by petitioners. This incident comes within the exclusive jurisdiction of the Court of Agrarian Relations. 1
WHEREFORE, the resolution of the agrarian court dated March 23, 1961, as well as its order denying petitioners’ motion for reconsideration dated April 11, 1961, are hereby set aside. The case is remanded to the agrarian court for further proceedings. Costs against Pilar Santos.
Bengzon, C.J., Padilla, Labrador, Concepcion, Barrera, Paredes, Dizon, Regala and Makalintal, JJ., concur.
Reyes, J.B.L., J., took no part.
Endnotes:
1. "SEC. 21 Ejectment; Violation; Jurisdiction. — All cases involving the dispossession of a tenant by the landholder or by a third party and/or the settlement and disposition of disputes arising from the relationship of landholder and tenant, as well as the violation of any of the provisions of this Act, shall be under the original and exclusive jurisdiction of such court as may now or hereafter be authorized by law to take cognizance of tenancy relations and disputes."
