[ G.R. No. L-18431, June 30, 1962 ]
RUFINO ALARCON, ET AL., PETITIONERS VS. PILAR SANTOS. ET AL., RESPONDENT.
D E C I S I O N
BAUTISTA ANGELO, J.:
PETITION for review the decision of the Court of Agrarian Relations.
Respondent Pilar Santos leased her lands to Dionisio Alarcon who in turn hired petitioners to till the same. When the lease contract was terminated the petitioners were forcibly ejected from their landholdings, respondent claiming that as owner of the lands she can exercise all rights that pertain to her ownership. The petitioners petitioned the Court of Agrarian Relations for reinstatement as tenants with damages. The agrarian court after due hearing, dismissed the case for lack of jurisdiction holding that no tenancy relationship exists between petitioners and respondent because this circumstance exists between petitioners and the lessee who was not made a party in the case. From this ruling the petitioners elevated the case for review. The Supreme Court set aside the appealed order and remanded the case for further proceedings with costs.
The findings of the trial court is an open infringement of the letter and spirit of Section 9 of RA No. 1199. The Court opined that even if there is a contract creating the leasehold or tenancy relationship, the mere expiration of the contract does not ipso facto terminate the relationship between the parties because the law imposes upon the new landholder or owner the duty to assume all the rights and obligations of the former landholder with the particularity that if the latter dies his heirs shall likewise assume the same rights and obligations. Should this eventuality happen, if the owner or transferee dispossess the tenants of the land the remedy of the tenants is to seek reinstatement with damages which comes squarely within the exclusive jurisdiction of the Court of Agrarian Relations.
SUMMARY
Respondent Pilar Santos leased her lands to Dionisio Alarcon who in turn hired petitioners to till the same. When the lease contract was terminated the petitioners were forcibly ejected from their landholdings, respondent claiming that as owner of the lands she can exercise all rights that pertain to her ownership. The petitioners petitioned the Court of Agrarian Relations for reinstatement as tenants with damages. The agrarian court after due hearing, dismissed the case for lack of jurisdiction holding that no tenancy relationship exists between petitioners and respondent because this circumstance exists between petitioners and the lessee who was not made a party in the case. From this ruling the petitioners elevated the case for review. The Supreme Court set aside the appealed order and remanded the case for further proceedings with costs.
RULING
The findings of the trial court is an open infringement of the letter and spirit of Section 9 of RA No. 1199. The Court opined that even if there is a contract creating the leasehold or tenancy relationship, the mere expiration of the contract does not ipso facto terminate the relationship between the parties because the law imposes upon the new landholder or owner the duty to assume all the rights and obligations of the former landholder with the particularity that if the latter dies his heirs shall likewise assume the same rights and obligations. Should this eventuality happen, if the owner or transferee dispossess the tenants of the land the remedy of the tenants is to seek reinstatement with damages which comes squarely within the exclusive jurisdiction of the Court of Agrarian Relations.