Facts:
Petitioners are
Marciana Alarcon,
Ercencio Austria,
Juan Bonifacio,
Petronila Dela Cruz,
Rufina Dela Cruz,
Celestino Legaspi,
Jose Mayondag, and
David Santos. Respondent is
Pascual and Santos, Inc. The controversy involved several
saltbeds owned by
Pascual and Santos, Inc. with an area of
4.1763 hectares, located in
Barangay San Dionisio, Manuyo, Paranaque. In
1950, the corporation instituted petitioners as
tenants of the saltbeds under a
fifty-fifty share tenancy agreement, and the tenurial relationship remained harmonious until
1994, when the
city government of Paranaque, then represented by
Mayor Pablo Olivares, authorized the
dumping of garbage on an adjoining lot. The garbage polluted the main source of salt water and adversely affected salt production on the saltbeds. Petitioners informed the corporation, but it did not take steps to stop the dumping. Petitioners then filed a formal protest with the City Government, but their complaint was ignored. Consequently, petitioners filed with the
Regional Agrarian Reform Adjudicator of Region IV (RARAD-IV) a complaint against
Pascual and Santos, Inc. and Mayor
Pablo Olivares for
maintenance of peaceful possession and security of tenure, with
damages. Petitioners later amended the complaint to one for
damages and disturbance compensation, with a prayer for
temporary restraining order and injunction, invoking
Sections 7,
30(1), and
31(1) of
Republic Act No. 3844, as amended. On
July 28, 1997, RARAD-IV rendered a decision holding that, under
Metro Manila Zoning Ordinance No. 81-01 issued in
1981, the saltbeds had been
reclassified to residential lands, and thus the juridical tie between landlord and tenant was severed because no tenurial relationship could exist on land no longer agricultural; it nonetheless ruled that petitioners were entitled to
disturbance compensation pursuant to
Section 36, par. 1 of
R.A. 3844, as amended. The RARAD-IV decision also held that the DAR had no jurisdiction over the complaint against Mayor Olivares and dismissed that portion. The dispositive portion ordered payment by the corporation to each complainant of
1,500 cavans of salt (or the money equivalent at prevailing market value) as disturbance compensation, and dismissed the rest. Petitioners appealed in the sense that respondent was the losing party before the DARAB and later moved the litigation through appeal: the
Department of Agrarian Reform Adjudication Board (DARAB) affirmed the RARAD-IV decision. Respondent then filed a petition for review with the
Court of Appeals, docketed as
CA-G.R. SP No. 63680. On
September 28, 2001, the Court of Appeals reversed, ordered the
dismissal of petitioners’ complaint against respondent, and denied petitioners’ motion for reconsideration. Petitioners thus filed the present petition for review on certiorari, principally challenging the Court of Appeals’ rejection of disturbance compensation.
Issues:
Whether a
mere reclassification of agricultural land to non-agricultural use, specifically under
Metro Manila Zoning Ordinance No. 81-01,
without a final court action ejecting or dispossessing the tenant at the instance of the landowner,
entitles the tenant to
disturbance compensation under
R.A. 3844, as amended.
Ruling:
Ratio:
Doctrine: