Facts:

The case at hand involves petitioners Marciana Alarcon, Erencio Austria, Juan Bonifacio, Petronila Dela Cruz, Rufina Dela Cruz, Celestino Legaspi, Jose Mayondag, and David Santos, who filed a joint petition against the respondents, the Honorable Court of Appeals and Pascual and Santos Inc., for a review on certiorari. On July 8, 2003, the Supreme Court heard the case after the Court of Appeals reversed the Department of Agrarian Reform Adjudication Board's (DARAB) decision dated January 10, 2001, which had originally favored the petitioners. The dispute arose from the tenurial relationship established in 1950 between the respondents (Pascual and Santos, Inc.) and the petitioners, who were designated as tenants of certain saltbeds comprising 4.1763 hectares located in Barangay San Dionisio, Manuyo, Parañaque City under a fifty-fifty share tenancy agreement. This relationship persisted until 1994, when the city government of Parañaque, led by then Mayor Pablo Olivares, initiat

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Facts:

Parties and Procedural History

• Petitioners: Marciana Alarcon, Erencio Austria, Juan Bonifacio, Petronila Dela Cruz, Rufina Dela Cruz, Celestino Legaspi, Jose Mayondag, and David Santos.
• Respondents: The Honorable Court of Appeals and Pascual and Santos, Inc., a corporation owning saltbeds.
• Initial procedural posture: Petition for review on certiorari filed to set aside the Court of Appeals’ decision reversing the Department of Agrarian Reform Adjudication Board (DARAB) ruling.

Underlying Tenurial Relationship and Land Details

• The subject property: Several saltbeds covering an area of 4.1763 hectares, located in Barangay San Dionisio, Manuyo, ParaAaque.
• Tenancy Agreement: Instituted in 1950 between respondent and petitioners under a fifty-fifty share tenancy arrangement establishing a landlord-tenant relationship on the saltbeds.

Events Disrupting the Tenurial Status Quo

• In 1994, the city government of ParaAaque, represented by then-Mayor Pablo Olivares, authorized the dumping of garbage on an adjoining lot, which polluted the main source of saltwater vital for salt production.
• Petitioners promptly informed the respondent of the adverse effects on salt production, but the respondent failed to take corrective action.
• The petitioners’ formal protest with the City Government was ignored, prompting them to file a complaint with the Regional Agrarian Reform Adjudicator of Region IV (RARAD-IV).

Filing and Content of the Complaint

• Initial Complaint: Petitioners sought maintenance of peaceful possession and security of tenure with damages.
• Amended Complaint: Later progressed into a suit for damages and disturbance compensation, with a prayer for a temporary restraining order and injunction.
• Statutory Basis: The complaint invoked Sections 7, 30(1), and 31(1) of Republic Act No. 3844 (Agricultural Land Reform Code of the Philippines).

Reclassification and Its Implications

• RARAD-IV Decision (July 28, 1997):
• Determined that under Metro Manila Zoning Ordinance No. 81-01 (1981), the saltbeds were reclassified to residential lands.
• Held that such reclassification severs the juridical tenurial tie between the parties because agricultural tenurial relations cannot subsist on a non-agricultural land.
• Nonetheless, provided that petitioners be entitled to disturbance compensation as provided under Section 36, paragraph 1, of RA 3844.
• Affirmation by DARAB: The Department of Agrarian Reform Adjudication Board affirmed the RARAD decision in toto.

Appeal and Contentions Raised

• Respondent’s Appeal: Pascual and Santos, Inc. filed a petition for review with the Court of Appeals challenging the payment of disturbance compensation.
• Respondent's Arguments:
• Asserted that a landowner’s payment of disturbance compensation is not triggered merely by reclassification without court-ordered ejectment or dispossession.
• Claimed that the statutory framework under Sections 30 and 31 of RA 3844 requires an active step (i.e., petitioning for ejectment) by the landowner.
• Petitioners’ Argument:
• Contended that the tenant’s rights are violated by the mere fact of reclassification, entitling them to disturbance compensation, independent of any court action initiated by the landowner.

Preliminary Jurisprudential and Statutory Issues

• Governing Law Issue:
• Whether the case should be governed by Republic Act No. 1199 (Agricultural Tenancy Act), which allows share tenancy, or by RA 3844 as amended, which converts share tenancy into leasehold and prohibits unauthorized dispossession.
• The respondent argued for RA 1199 based on Section 35 of RA 3844, but this was rebutted citing the repeal of Section 35 by Section 76 of Republic Act No. 6657.
• Main Question: Is the mere reclassification of land, without a final court judgment authorizing ejectment, sufficient to trigger the landowner’s obligation to pay disturbance compensation?

Issue:

Governing Statutory Framework

• Does Republic Act No. 3844, as amended, govern the tenancy relationship for saltbeds despite provisions in RA 1199?
• Is the exemption provided by Section 35 of RA 3844 operable, or is it rendered null by subsequent legislative repeal?

Tenurial Relationship and Disturbance Compensation

• Does a mere reclassification of agricultural land to residential, in the absence of court-ordered ejectment, extinguish the established tenurial relationship?
• Can the tenant claim disturbance compensation when the reclassification is not accompanied by a final and executory judgment authorizing ejectment?

Burden of Proof in Ejectment Cases

• Who bears the burden of proof to establish that the tenant’s ejectment was warranted under the conditions provided in Section 36 of RA 3844?
• Is it sufficient for the tenant to assert disturbance to claim compensation, or must the landowner first initiate court proceedings leading to ejectment?

Ruling:

• (Subscriber-Only)

Ratio:

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Doctrine:

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