Title
Joya vs. Pareja
Case
G.R. No. L-13258
Decision Date
Nov 28, 1959
The court upheld the tenant's right to cultivate the land post-lease expiration, affirming judicial authority over rental fee determination.
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Case Digest (G.R. No. L-13258)

Facts:

  • The case involves petitioners Florentino Joya, Juan Tahimic, and Domingo Joya against respondent Pedro Pareja.
  • The events occurred in Tanza, Cavite, with a decision made on November 28, 1959.
  • Florentino Joya owned an 11-hectare parcel of land (Lot No. 1171) leased to Maximina Bondad for 16 years.
  • Pedro Pareja worked the land as Bondad's tenant during the lease.
  • After the lease ended in April 1954, Joya sought to lease the land again but could not agree on rental terms with Pareja.
  • Joya demanded 120 cavanes of palay as annual rent, while Pareja continued to cultivate the land.
  • On May 24, 1954, Pareja filed a complaint with the Court of Industrial Relations for a rental reduction, which Joya denied.
  • Joya subsequently leased the land to Domingo Joya, allowing Pareja to cultivate it under a profit-sharing agreement.
  • In April 1955, Joya renewed the lease with Domingo and included Juan Tahimic, reducing the rent to 105 cavanes.
  • Pareja refused to vacate, prompting Joya to file a usurpation complaint against him.
  • Pareja was arrested but later counter-charged Joya and co-defendants for violating Republic Act 1199.
  • Pareja withdrew his complaint, opting to let the court determine his rights.
  • On January 31, 1956, Pareja filed a complaint in the Court of Agrarian Relations against Joya and Tahimic for unlawful ejectment, seeking reinstatement, crop shares, damages, and attorney's fees.
  • The Agrarian Court ruled Pareja had an automatic tenancy right upon lease termination, ordering his reinstatement to half the land and recognizing Domingo and Juan as joint tenants of the other half.
  • The court also ordered the return of overpaid rentals to Pareja and the co-lessees, exonerating Joya and co-defendants from violating Republic Act 1199.

Issue:

  • (Unlock)

Ruling:

  • Yes, the court ruled that a tenant of a lessee retains the right to work on the land despite the lease's termination.
  • The court upheld the rental amount determined by the Agrarian Court as valid.
  • The court found that P...(Unlock)

Ratio:

  • The court's decision was based on the interpretation of Republic Act 1199, particularly Section 9, which states that the expiration of a lease does not extinguish the tenancy relationship.
  • The court emphasized that tenant rig...continue reading

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