G.R. No. L-54290. May 31, 1988.
DON PEPE HENSON ENTERPRISES and VICENTE HENSON, petitioners, vs. IRINEO PANGILINAN, MELQUIADES GUZMAN, MARCIAL DAYRIT, JUAN PANGILINAN, MARIANO DAVID, and the HON. COURT OF APPEALS, respondents.

FACTS

Petitioners, Don Pepe Henson Enterprises and Vicente Henson, own agricultural lands in Pampanga. On February 2, 1966, they executed a year-to-year civil law lease over a portion to Faustino Ocampo. Private respondents (Irineo Pangilinan, et al.) were allowed by Ocampo to till specific parcels within this leased area, paying him a share of the harvest. After Ocampo’s death in 1972 and the subsequent surrender of the leasehold by his son, petitioners entered into a new agreement with private respondents, allowing them to continue farming. However, in November 1972, petitioners leased the land to another party, Augusta Ayson, and subsequently attempted to evict private respondents to develop the land into subdivisions. This prompted private respondents to file an action for injunction with the Court of Agrarian Relations (CAR) to protect their possession.
The CAR ruled that private respondents were lawful leasehold tenants entitled to security of tenure, a decision affirmed by the Court of Appeals. Petitioners sought review, arguing insufficient evidence of tenancy, noting the absence of rental receipts and claiming the civil law lease with Ocampo was coerced. They also pointed out that two respondents, Mariano David and Juan Pangilinan, had previously executed documents of surrender and received disturbance compensation for other landholdings, though the lands in dispute were different.

ISSUE

Whether a tenancy relationship existed between the petitioners and the private respondents, entitling the latter to security of tenure.

RULING

The Supreme Court denied the petition and affirmed the appellate court’s decision, upholding the existence of a tenancy relationship and the corresponding security of tenure for private respondents. The legal logic rests on the application of agrarian laws and the nature of tenancy relations. The Court found that a tenancy relationship was established between Faustino Ocampo, as the civil law lessee of the landholding, and the private respondents, who personally cultivated the land and shared the harvest. This relationship is not extinguished merely by the expiration or termination of the civil law lease contract between the landowner and the lessee. Under Section 10 of Republic Act No. 3844 (Agricultural Land Reform Code), the agricultural leasehold relation is not extinguished by the expiration of the period or the surrender of the land by the lessee.
Consequently, upon Ocampo’s death and the surrender of the lease, the private respondents’ status as tenants continued. The petitioners, as landowners, were subrogated to the rights and obligations of their lessee, Ocampo, concerning these tenants. The Court dismissed the relevance of the prior surrender documents executed by two respondents for other lands, as the tenancy in the present case involved distinct parcels and was established under Ocampo’s leasehold. The alleged agreements (“Picasunduan”) where respondents purportedly relinquished possession were unenforceable for contravening the security of tenure provisions of agrarian law. The certification from the Ministry of Agrarian Reform listing respondents as farmer beneficiaries further reinforced the factual finding of tenancy. Thus, as bona fide tenants, private respondents are entitled to security of tenure and protection from ejectment absent lawful grounds for termination.