Case Digest (G.R. No. L-29381)
Facts:
Philippine National Railways and Pantaleon Bingabing, Petitioners, vs. Hon. Valeriano A. Del Valle, in his capacity as Presiding Judge, Court of Agrarian Relations and Pampilo Doltz, Respondents, G.R. No. L-29381. September 30, 1969, Supreme Court En Banc, Sanchez, J., writing for the Court.Philippine National Railways (PNR), a government-owned corporation, owned three contiguous longitudinal strips of land, each 30 meters wide, forming part of its railroad right of way between Manila and Legazpi within the municipalities of Oas and Polangui, Albay. The central portion contained the track (10–12 meters wide); on both sides, at about 2–5 meters from the embankment, telegraph and telephone posts stood at roughly 50-meter intervals. PNR used the side strips for communication lines, to draw earth for track repairs after washouts, and as storage for materials needed to repair damaged parts of the line.
To regulate occupation of the portions not essential to trackbed, PNR adopted temporary rules: public competitive bidding for possession; rentals fixed by highest bid; leases limited to three years; prohibition of sublease; revocability of leases on demand when PNR needed the land; right of entry for repairs; and a prohibition on uses prejudicial to train operation. Pursuant to these rules, PNR awarded the side strips to Pantaleon Bingabing after competitive bidding; a printed civil lease dated April 15, 1963, identified the use as "temporarily for agriculture" and fixed rent at P130 per annum. Bingabing failed to take physical possession because Pampilo Doltz occupied portions, had constructed a small house, and claimed tenancy as a successor to prior occupants.
In March 1965 PNR and Bingabing filed Civil Case No. 3021 in the Court of First Instance (CFI) of Albay for recovery of possession, damages and other reliefs against Doltz. Doltz answered that he had been a tenant for over twenty years under successive awardees and invoked tribunal jurisdiction of the Court of Agrarian Relations (CAR); the CFI action is noted in the record but its disposition had not reached this Court. While Civil Case No. 3021 was pending, Doltz registered a petition with the CAR (CAR Case No. 692, Albay ’67) seeking security of tenure, a 70–30 crop-sharing ratio in his favor and reliquidation; PNR intervened. CAR, after trial, held it had jurisdiction, declared Dolt...(Subscriber-Only)
Issues:
- Is the disputed strip-of-right-of-way land an agricultural land within the meaning of the Agricultural Tenancy Act and the Agricultural Land Reform Code such that the Court of Agrarian Relations has jurisdiction?
- If the land were agricultural, is Pampilo Doltz a true and lawful tenant entitled to the security of tenure and othe...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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