Case Summary (G.R. No. L-44587)
Applicable Law
– 1973 Philippine Constitution, Article X, Section 11(1) (jurisdictional period for agrarian cases)
– Agricultural Tenancy Act (Republic Act No. 3844)
– Republic Act No. 1199, as amended (tenancy provisions for sugarlands, fishponds, saltbeds)
Factual Background
In 1950, Espiritu leased a fishpond from the Buenaventuras for an annual rental of ₱1,000, payable in advance, with an obligation to maintain the property and supply water to adjacent saltbeds. In 1955, he additionally leased 18 of the petitioners’ 200 saltbeds, working them under a share-tenancy arrangement.
Demand to Vacate and Agrarian Complaint
In November 1972, the petitioners demanded Espiritu’s vacatur, alleging breach of lease conditions. Espiritu left but promptly filed a complaint before the Court of Agrarian Relations with assistance from the Bureau of Agrarian Legal Assistance, challenging his eviction.
Procedural History and Jurisdiction
The Court of Agrarian Relations ruled for Espiritu, a decision the Court of Appeals affirmed. The petitioners sought relief by certiorari under Rule 45, contending that the agrarian court lost jurisdiction upon lapse of the reglementary period under the 1973 Constitution.
Jurisdictional Issue and Precedents
The Supreme Court dismissed the jurisdictional challenge, citing settled precedents (Marcelino v. Cruz; New Frontier Mines v. NLRC; Federation of Free Farmers v. Court of Appeals) and noting that the issue is academic under subsequent constitutional provisions.
Nature of the Lease Relationship
Both trial and appellate courts found Espiritu to be an agricultural lessee of the fishpond and a share tenant of the saltbeds, dividing produce equally with the petitioners. These findings, grounded on substantial evidence and free of grave abuse of discretion, establish the relationship as governed by agrarian tenancy laws rather than the Civil Code.
Rental Payment and Tenancy Classification
The petitioners’ reliance on advance payment to characterize the lease as civil is unfounded. Under Section 46 of RA 1199 (as amended), parties may stipulate consideration for fishponds and saltbeds. Advance or fixed monetary rentals remain an element of agricultural tenancy pursuant to the Agricultural Tenancy Act.
Security of Tenure and Prohibition on Dispossession
As an agricultural lessee and
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Procedural History
- Petitioners filed a Rule 45 petition for certiorari to review the Court of Appeals decision affirming the Court of Agrarian Relations.
- The following timeline of events emerged:
• 1950 – Rafael Espiritu leased petitioners’ fishpond for an annual rent of ₱1,000, payable in advance, plus an obligation to maintain the pond and furnish water for the petitioners’ saltbed.
• 1955 – Espiritu additionally leased 18 out of 200 saltbeds from petitioners, which he cultivated alongside the fishpond.
• November 1972 – Petitioners demanded Espiritu vacate the premises for alleged breach of lease conditions.
• Post-vacation – Espiritu sought intervention from the Bureau of Agrarian Legal Assistance and filed a complaint with the Court of Agrarian Relations.
• Agrarian court ruled in favor of Espiritu; Court of Appeals sustained this decision.
Facts of the Case
- The lease agreements covered two types of agricultural properties: a fishpond and saltbeds.
- Rental for the fishpond was fixed at ₱1,000 per annum, paid in advance.
- Saltbeds’ yield was shared equally between Espiritu and the petitioners.
- Petitioners alleged lease conditions had been violated and secured a notice to vacate.
- Espiritu complied with the notice but maintained he was unlawfully dispossessed.
Issues
- Whether the Court of Agrarian Relations lost jurisdiction due to the lapse of the reglementary period under Section 11(1), Article X of the 1973 Constitution.
- Whether the lease contracts are governed by the Civil Code or by the Agricultural Tenancy Act and related agrarian statutes.
- Whether advance payment of rent transforms an agricultural tenancy into a civil lease.
- Whether fishponds and saltbeds fall outside the share‐tenancy system of Rep. Act No. 3844.
- Whether Espiritu abandoned the property or was unlawfully coerced to vacate.
- Whether Espiritu’s personal or family wealth negates his status as an agricultural lessee or share tenant.
Jurisdictional Challenge
- Petitioners contended the agrarian court lost jurisdiction after the prescribed period under the 1973 Constitution.