Facts:

• Rufino Alarcon and other tenants filed a petition for reinstatement and damages against Pilar Santos before the Court of Agrarian Relations of Pangasinan.
• The tenants were forcibly ejected by Pilar Santos after the expiration of their lease contract.
• The land they were working on belonged to Pilar Santos but was leased to Dionisio Alarcon, who employed them as tenants.
• Dionisio Alarcon was not made a party respondent in the case.
• The agrarian court dismissed the petition for want of jurisdiction, stating that there was no tenancy relationship between the petitioners and Pilar Santos since Dionisio Alarcon was not included as a respondent.

Issue:

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Ruling:

• The Supreme Court ruled in favor of the tenants and remanded the case for further proceedings.
• The agrarian court's dismissal of the petition for want of jurisdiction was set aside.
• The Supreme Court held that the mere expiration of the lease contract does not terminate outright the tenancy relationship between the parties.
• The law imposes upon the new landholder or owner the duty to assume all the rights and obligations of the former landholder, including the rights and obligations towards the tenants.
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Ratio:

• The Supreme Court based its decision on Section 9 of the Agricultural Tenancy Act, which states that the expiration of the lease contract does not extinguish the tenancy relationship.
• The new landholder or owner is obligated to assume the rights and obligations of the former landholder.
• If the tenants are dispossessed,...continue reading