9.) SPOUSES TITUS L. ENDAYA and GLENDA TRINIDAD; SPOUSES RICO L.

landowners, the Spouses San Diego, entered into a lease contract with Regino
ENDAYA and NANETTE AQUINO; and SPOUSES JOSEPHINE L. ENDAYA and Cassanova, the agricultural leasehold relationship between the Spouses San Diego
LEANDRO BANTUG, petitioners, vs. COURT OF APPEALS and PEDRO FIDELI, and private respondent, the existence of which petitioners do not dispute, was thereby
respondents. terminated. Petitioners argue that a landowner cannot have a civil law lease contract
G.R. No. 88113 October 23, 1992 with one person and at the same time have an agricultural leasehold agreement with
another over the same land.
DOCTRINE: Transactions involving the agricultural land over which an agricultural
leasehold subsists resulting in change of ownership, e.g., sale, or transfer of legal ISSUE: Whether or not Fideli is an agricultural tenant of the petitioner? YES
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 HELD:
the landowner's successor in interest.
R.A. No. 3844 (1963), as amended By R.A. No. 6839 (1971), which is the relevant
FACTS: law governing the events at hand, abolished share tenancy throughout the Philippines
from 1971 and established the agricultural leasehold system by operation of law.
 The Spouses Natividad Trinidad and Cesar San Diego owned a piece of
agricultural land situated at San Pioquinto, Malvar, Batangas, devoted to rice Section 7 of the said law gave agricultural lessees security of tenure by providing
and corn. the following: "The agricultural leasehold relation once established shall confer upon
 As far back as 1934, private respondent Fideli has been cultivating this land the agricultural lessee the right to continue working on the landholding until such
as a tenant of the Spouses respondent Fideli has been cultivating this land as leasehold relation is extinguished. The agricultural lessee shall be entitled to security
a tenant of the Spouses San Diego under a fifty-fifty (50-50) sharing of tenure on his landholding and cannot be ejected therefrom unless authorized by the
agreement. Court for causes herein provided."
 On May 2, 1974, a lease contract was executed between the Spouses San
Diego and one Regino Cassanova for a period of four years from May 1974 The fact that the landowner entered into a civil lease contract over the subject
up to May 1978. The lease contract obliged Cassanova to pay P400.00 per landholding and gave the lessee the authority to oversee the farming of the land, as
hectare per annum and gave him the authority to oversee the planting of crops was done in this case, is not among the causes provided by law for the extinguishment
on the land. of the agricultural leasehold relation. 13 On the contrary, Section 10 of the law provides:
 The lease contract was subsequently renewed but the rental was raised to
P600.00. Again, private respondent signed the contract as witness. Sec. 10. Agricultural Leasehold Relation Not Extinguished by Expiration of
 During the entire duration of the lease contract between the Spouses San Period, etc. — The agricultural leasehold relation under this code shall not be
Diego and Cassanova, private respondent continuously cultivated the land, extinguished by mere expiration of the term or period in a leasehold contract nor by the
sharing equally with Cassanova the net produce of the harvests. sale, alienation or transfer of the legal possession of the landholding. In case the
 Spouses San Diego then sold the land to petitioners for the sum of agricultural lessor sells, alienates or transfers the legal possession of the landholding,
P26,000.00. the purchaser or transferee thereof shall be subrogated to the rights and substituted to
 Private respondent continued to farm the land although petitioners claim that the obligations of the agricultural lessor.
private respondent was told immediately after the sale to vacate the land.
Hence, transactions involving the agricultural land over which an agricultural leasehold
 In any case, it is undisputed that private respondent deposited with the Luzon
subsists resulting in change of ownership, e.g., sale, or transfer of legal possession,
Development Bank an amount of about P8,000.00 as partial payment of the
such as lease, will not terminate the right of the agricultural lessee who is given
landowner's share in the harvest for the years 1980 until 1985.
protection by the law by making such rights enforceable against the transferee or the
 Due to petitioners persistent demand for private respondent to vacate the
landowner's successor in interest.
land, private respondent filed a Complaint with the RTC praying that he be
declared the agricultural tenant of petitioners.
In the instant case, private respondent has been cultivating the subject farm landholding
with a fifty-fifty (50-50) sharing arrangement with the Spouses San Diego, petitioners'
RTC: Held that private respondent is not an agricultural lessee of the land now owned
predecessors-in-interest. The passage of R.A. 6839 in 1971, amending R.A. 3844
by petitioners. It ordered the private respondent to vacate the land.
(1963), secured to private respondent all the rights pertaining to an agricultural lessee.
CA: reversed the RTC decision and declared private respondent to be the agricultural
The execution of a lease agreement between the Spouses San Diego and Regino
lessee of the subject landholding.
Cassanova in 1974 did not terminate private respondent's status as an
agricultural lessee. The fact that private respondent knew of, and consented to,
Petitioner’s contention:
the said lease contract by signing as witness to the agreement may not be
Petitioners impugn the Court of Appeals' declaration that private respondent is an
construed as a waiver of his rights as an agricultural lessee.
agricultural lessee of the subject landholding contending that when the original
On the contrary, it was his right to know about the lease contract since, as a result of
the agreement, he had to deal with a new person instead of with the owners directly as
he used to. No provision may be found in the lease contract and the renewal contract
even intimating that private respondent has waived his rights as an agricultural lessee.

Militating against petitioners' theory that the agricultural leasehold was terminated or
waived upon the execution of the lease agreement between the San Diegos and
Cassanova is the fact the latter desisted from personally cultivating the land but left it
to private respondent to undertake the farming, the produce of the land being shared
between Cassanova and private respondent, while the former paid P400.00 and later
P600.00 per hectare per annum to the San Diegos, as agreed upon in the lease
contract.

Petitioners, however, insist that private respondent can no longer be considered the
agricultural lessee of their farm land because after they purchased the land from the
Spouses San Diego in 1980, private respondent did not secure their permission to
cultivate the land as agricultural lessee.

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 shows, acquiring not only their
rights but also their obligations.

In fine, the Court, after a painstaking examination of the entire records of the case and
taking into account the applicable law, as well as the relevant jurisprudence, rules that
private respondent is the agricultural lessee over the land owned by petitioners. As
such, private respondent's security of tenure must be respected by petitioners.

WHEREFORE, premises considered, the Petition is DISMISSED and the decision of

SO ORDERED.