G.R. No. L-44587 - Spouses Buenaventura vs. Court of Appeals

In 1950, Rafael Espiritu (private respondent) leased from spouses Amado and Irene Buenaventura (petitioners) a fishpond for an annual rent of ₱1,000, payable in advance. He agreed to maintain the pond and supply water for the petitioners’ saltbed.
In 1955, Espiritu additionally leased 18 out of the petitioners’ 200 saltbeds, which he also cultivated alongside the fishpond. The produce from the saltbeds was divided equally between the parties.

In November 1972, petitioners served Espiritu a notice to vacate, alleging he violated lease conditions. Espiritu vacated but later sought the assistance of the Bureau of Agrarian Legal Assistance.
With bureau support, he filed a complaint before the Court of Agrarian Relations (CAR) for illegal dispossession and invocation of agrarian tenancy protection.
The CAR ruled in favor of Espiritu; on appeal, the Court of Appeals (CA) affirmed. Petitioners then filed a Rule 45 petition for certiorari before the Supreme Court.

Petitioners contended CAR lost jurisdiction due to the lapse of the reglementary period under Section 11(1), Article X of the 1973 Constitution.
The CA and subsequently the Supreme Court rejected this contention, citing precedents deeming the issue resolved and academic under the 1987 Constitution.

Whether the CAR retained jurisdiction over the agrarian tenancy dispute despite alleged lapse of the reglementary period.
Whether the lease contracts for fishpond and saltbeds are governed by the Civil Code or by agrarian tenancy laws (RA 3844 as amended by RA 1199).
Whether fishponds and saltbeds fall within the share tenancy system and thus entitle Espiritu to security of tenure under agrarian legislation.