Professional Documents
Culture Documents
1 Endaya Vs CA
1 Endaya Vs CA
CA
NATURE OF THE CASE: Petition for Review on Certiorari assailing the decision of the Court of Appeals
reversing the judgment of the RTC.
FACTS:
1. Spouses Trinidad and San Diego owned a piece of agricultural land consisting of 20,200 square meters
situated at Batangas, devoted for rice and corn. It is undisputed that as far back as 1934, private
respondent Fideli has been cultivating the land as a tenant of the Spouses under a 50-50 sharing
agreement.
2. On 1974, a lease contract was executed between the Spouses San Diego and one Regino Cassanova
for a period of 4 years from 1974-1978. The lease contract obliged Cassanova to pay P400 per hectare
per annum and gave him authority to oversee the planting of crops of the land. Private respondent
signed the lease contract as one of 2 witnesses.
3. The lease contract was subsequently renewed to last until 1980 but the rental was raised to P600.
Again, private respondent signed the contract as witness.
4. During the entire duration of the lease contract between the Spouses San Diego and Cassanova,
private respondent continuously cultivated the land, sharing equally with Cassanova the net produce of
the harvests.
5. On 1980, the Spouses San Diego sold the land to petitioners. The sale was registered with the Register
of deeds of Batangas and a TCT was issued. Private respondent continued to farm the land although
petitioners claim that private respondent was told immediately after the sale to vacate the land. In any
case, it is undisputed that private respondent deposited with the Luzon Development Bank a partial
payment of the landowner’s share in the harvest for the years 1980 until 1985.
6. Due to petitioners persistent demand for private respondent to vacate the land, private respondent
filed a complaint with the RTC praying that he be declared the agricultural tenant of petitioners.
RTC Ruling: After the trial, the trial court decided in favor of the petitioners by holding that private
respondent is not an agricultural lessee of the land now owned by the petitioners.
CA Ruling: The Court of Appeals rendered the reversed the RTC decision and declared private
respondent to be the agricultural lessee of the subject landholding.
Hence, this petition wherein private respondent’s status as an agricultural lessee and his security of
tenure as such are being disputed by petitioners.
ISSUE/S:
1. WON the lease contract entered into by the original landowners with Cassanova terminates the
agricultural leasehold relationship between the Spouses and the private respondent.
2. WON the private respondent can no longer be considered as an agricultural lessee because after they
purchased the land from the Spouses, the private respondent did not secure their permission to
cultivate the land as an agricultural lessee.
Case for Petitioner: Petitioner contends that when the original landowners, the Spouses San Diego,
entered into a lease contract with Cassanova, the agricultural leasehold relationship between Spouses
San Diego and private respondent was thereby terminated. Petitioners argue that a landowner cannot
have a civil law lease contract with one person and at the same time have an agricultural leasehold
agreement with another over the same land. It is further argued that because private respondent
consented to the lease contract between the Spouses San Diego and Cassanova, signing as he did the
lease agreement and the renewal contract as witness, private respondent has waived his rights as an
agricultural lessee. Petitioner also contends that after they purchased the land from the Spouses, private
respondent did not secure their permission to cultivate the land as an agricultural lessee.
Case for Private Respondent: Private respondent has been cultivating the subject farm landholding with
a 50-50 sharing arrangement with the Spouses San Diego, petitioner’s predecessors-in-interest
1. NO. R.A. No. 3844 (1963), as amended By R.A. No. 6839 (1971), which is the relevant law governing
the events at hand, abolished share tenancy throughout the Philippines from 1971 and established the
agricultural leasehold system by operation of law. Section 7 of the said law gave agricultural lessees
security of tenure by providing the following: "The agricultural leasehold relation once established shall
confer upon the agricultural lessee the right to continue working on the landholding until such leasehold
relation is extinguished. The agricultural lessee shall be entitled to security of tenure on his landholding
and cannot be ejected therefrom unless authorized by the Court for causes herein provided." The fact
that the landowner entered into a civil lease contract over the subject landholding and gave the lessee
the authority to oversee the farming of the land, as was done in this case, is not among the causes
provided by law for the extinguishment of the agricultural leasehold relation. Section 10 of the law
provides:
Sec. 10. Agricultural Leasehold Relation Not Extinguished by Expiration of Period, etc. — The agricultural
leasehold relation under this code shall not be extinguished by mere expiration of the term or period in
a leasehold contract nor by the sale, alienation or transfer of the legal possession of the landholding. In
case the agricultural lessor sells, alienates or transfers the legal possession of the landholding, the
purchaser or transferee thereof shall be subrogated to the rights and substituted to the obligations of
the agricultural lessor.
Hence, transactions involving the agricultural land over which an agricultural leasehold subsists
resulting in change of ownership, e.g., sale, or transfer of legal possession, such as lease, will not
terminate the right of the agricultural lessee who is given protection by the law by making such rights
enforceable against the transferee or the landowner's successor in interest.
2. NO. It is true that the Court has ruled that agricultural tenancy is not created where the consent the
true and lawful owners is absent. But this doctrine contemplates a situation where an untenanted farm
land is cultivated without the landowner's knowledge or against her will or although permission to work
on the farm was given, there was no intention to constitute the worker as the agricultural lessee of the
farm land. The rule finds no application in the case at bar where the petitioners are successors-in-
interest to a tenanted land over which an agricultural leasehold has long been established. The
consent given by the original owners to constitute private respondent as the agricultural lessee of the
subject landholding binds private respondents whom as successors-in-interest of the Spouses San
Diego, step into the latter's shoes, acquiring not only their rights but also their obligations.
Contradicting their position that no agricultural leasehold exists over the land they acquired from the
Spouses San Diego, petitioners also pray for the termination of the tenancy of private respondent
allegedly due to: (a) non-payment of the agricultural lease rental; and (b) animosity between the
landowners and the agricultural lessee. The Court, however, observes that nowhere in the petitioners'
Answer to private respondent's Complaint or in the other pleadings filed before the trial court did
petitioners allege grounds for the termination of the agricultural leasehold. Well-settled is the rule
that issues not raised in the trial court cannot be raised for the first time on appeal.
WHEREFORE, premises considered, the Petition is DISMISSED and the decision of the Court of Appeals
AFFIRMED. Private respondent is hereby ordered to pay the back rentals from 1980 until 1992 plus
interest at the legal rate. An accounting of the production of the subject landholding is to be made by
private respondent to the Regional Trial Court of Tanauan, Batangas which shall determine the amount
due to petitioners based on the rate ordered above.