Case Digest (G.R. No. L-11920)
Facts:
The case involves Juan V. Agustin as the petitioner and Hon. Judge Pastor L. de Guzman of the Court of Agrarian Relations and Roman Guerrero as the respondents. The events leading to the case began on February 13, 1951, when Roman Guerrero, the owner of Lot No. 728 in the Cadastral Survey of Rizal, Nueva Ecija, leased approximately 17 hectares of land to Juan V. Agustin for a period of four years, with an annual rental of 400 cavans of palay, each weighing 46 kilos. On December 17, 1952, the lease was extended to ten years. However, on November 26, 1954, due to Guerrero selling about 5 hectares of the land to another party, Agustin relinquished his leasehold rights to that portion, reducing the leased area to about 12 hectares and adjusting the rental accordingly. Subsequently, on April 12, 1955, Agustin surrendered an additional 5 hectares for a payment of P1,000 from Guerrero, further reducing the leased area to approximately 7 hectares.
Following these transactions, Gue...
Case Digest (G.R. No. L-11920)
Facts:
Lease Agreement and Terms
- On February 13, 1951, Roman Guerrero, the owner of Lot No. 728 (approximately 17 hectares) in Nueva Ecija, leased the land to Juan V. Agustin for four years at an annual rental of 400 cavans of palay (46 kilos per cavan).
- On December 17, 1952, the lease term was extended to ten years.
Reduction of Leased Area
- On November 26, 1954, Agustin relinquished his leasehold rights to 5 hectares of the land after Guerrero sold that portion to another party. This reduced the leased area to about 12 hectares, with a corresponding decrease in the annual rental. The lease term was also shortened to end on January 30, 1958.
- On April 12, 1955, Agustin surrendered an additional 5 hectares in exchange for P1,000 paid by Guerrero, further reducing the leased area to about 7 hectares.
Complaint for Ejectment and Back Rentals
- Guerrero filed a complaint with the Court of Agrarian Relations to eject Agustin for allegedly failing to comply with the lease terms. Guerrero also sought to recover back rentals, taxes, and irrigation fees.
Motion to Dismiss
- Agustin filed a motion to dismiss the complaint, arguing that the Court of Agrarian Relations lacked jurisdiction because the relationship between him and Guerrero was that of a lessor and lessee, not a landlord and tenant.
Trial Court Decision
- The trial court denied Agustin’s motion to dismiss and ruled in favor of Guerrero. It authorized Guerrero to eject Agustin and place other tenants of his choice. Agustin was also ordered to pay back rentals for specific agricultural years and irrigation fees.
Issue:
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Ruling:
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Ratio:
Jurisdiction of the Court of Agrarian Relations
- The Court of Agrarian Relations has jurisdiction over cases involving leasehold tenancy. The facts of the case, including the size of the land (initially 17 hectares, later reduced to 7 hectares) and the nature of the agreement, supported the conclusion that the relationship was one of leasehold tenancy.
Definition of Leasehold Tenancy
- Under Section 4 of Republic Act No. 1199, leasehold tenancy exists when a person cultivates agricultural land belonging to another in consideration of a fixed amount or percentage of the produce. The land in question was cultivable by a single person with the help of their immediate household, satisfying the requirements of leasehold tenancy.
Agustin’s Allegations
- Agustin claimed that he did not personally cultivate the land but employed his own tenants. However, this claim was unsupported by evidence and was contradicted by Guerrero’s assertions and the stipulation of facts in the case.
Comparison with Other Cases
- The Court distinguished this case from Rural Progress Administration vs. Rufino Dimson, where the leased land was 323 hectares, making it impossible for a single person to cultivate. In contrast, the 7-hectare land in this case was within the capacity of a single person and their household to cultivate.
Conclusion
- The Court found that the relationship between Agustin and Guerrero was one of leasehold tenancy, and the Court of Agrarian Relations had jurisdiction over the case. The decision of the lower court was affirmed, and Agustin was ordered to pay the costs.