Title
Carag vs. Court of Appeals
Case
G.R. No. L-48140
Decision Date
Jun 18, 1987
Landowner Carag sued Ibay for unlawful detainer over leased farmland. Courts ruled no tenancy existed due to lack of personal cultivation, affirming municipal court's jurisdiction over civil lease dispute.
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Case Digest (G.R. No. L-48140)

Facts:

Ownership and Leasing of the Land:
Petitioner Miguel B. Carag is the registered owner of a 25-hectare parcel of land in Solana, Cagayan, identified as Lot 8137-C. In 1955, Carag’s father, Tomas Carag (who was also the overseer), verbally leased an 11-hectare portion of the land to respondent Leocadio Ibay. The lease terms included no rental for the first three years, followed by a 70-30 sharing of the harvest.

Revised Lease Terms:
In 1961, the leasing parties agreed to new terms: Ibay would pay 15 cavans of palay per hectare for the main crop and 10 cavans per hectare for the second crop. Ibay fully paid the rentals except for the 1970-71 crop year, leaving a balance of 35 cavans for the main crop and 110 cavans for the second crop unpaid.

Improvements and Detainer Complaint:
Ibay introduced improvements to the land, including a bodega (storage building) and an irrigation system, which enabled second crop planting. Despite repeated demands from Carag, Ibay refused to surrender possession. On April 2, 1971, Carag filed a complaint for unlawful detainer with damages before the Municipal Court of Solana.

Trial Court Findings:
The municipal court ruled that there was no agricultural leasehold relationship and applied the Civil Code on civil lease. It ordered Ibay to vacate the land, pay the unpaid rentals, and remove his bodega if Carag chose not to pay half its value. The decision became final, and a writ of execution was issued on March 14, 1972.

Annulment of Decision:
Before the execution of the decision, Ibay filed an action to annul the municipal court’s decision before the Court of First Instance of Cagayan, claiming that the case fell under the jurisdiction of the Court of Agrarian Relations due to an alleged agricultural leasehold relationship. The Court of First Instance ruled in favor of Ibay, nullifying the municipal court’s decision for lack of jurisdiction. The Court of Appeals affirmed this decision.

Issue:

  1. Whether there was an agricultural tenancy relationship between the parties, thus placing the case under the jurisdiction of the Court of Agrarian Relations.
  2. Whether the municipal court had jurisdiction to decide the case if no tenancy relationship existed.
  3. Whether the appellate court erred in affirming the trial court’s decision nullifying the municipal court’s judgment.

Ruling:

The Supreme Court set aside the decision of the Court of Appeals and reinstated the decision of the Municipal Court of Solana. It ruled that no agricultural tenancy relationship existed between the parties. Ibay’s admission that he employed laborers to cultivate the land negated the essential element of personal cultivation required for a tenancy relationship. The case was deemed a civil lease, and the municipal court had jurisdiction to decide the matter.

Ratio:

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