G.R. No. L-17649; July 31, 1963
ESTEBAN TAWATAO and LOURDES DEL ROSARIO, petitioners, vs. EUGENIO GARCIA, VIRGINIA DE VERA and HON. LEON P. DACAYO, Judge of the Court of Agrarian Relations (First Regional District) Lingayen, Pangasinan, respondents.

FACTS

Respondents Eugenio Garcia and Virginia de Vera filed a petition in the Court of Agrarian Relations (CAR), alleging they had been tenants of a nipa land since 1935, owned by the spouses Juliana Claudio and Pablo Tawatao. In 1950, they agreed with the owners to convert the land into a fishpond, sharing expenses and products equally. The respondents spent P830 for the conversion. After construction, the owners failed to pay their share. From 1950 to February 1955, the parties shared the fish harvests. In 1955, the owners leased the fishpond to a third party over the respondents’ objections. In 1956, the owners donated the fishpond to their children, the petitioners Esteban Tawatao and Lourdes del Rosario, who took possession and refused to restore it to the respondents. The respondents prayed for reinstatement as tenants and payment of damages.
The petitioners, as respondents in the CAR case, denied the material allegations, claimed the respondents had left the fishpond in 1955, and asserted the subsequent lease and donation were valid. After the petitioners’ counsel failed to appear at a duly noticed hearing, the CAR allowed the respondents to present evidence ex parte. The CAR rendered judgment ordering the petitioners to reinstate the respondents as tenants of the fishpond and to pay damages.

ISSUE

Whether the Court of Agrarian Relations has jurisdiction over a tenancy dispute involving a fishpond.

RULING

Yes, the Court of Agrarian Relations has jurisdiction. The petitioners argued that Republic Act No. 1199 , the Agricultural Tenancy Act, applies only to agricultural lands “for cultivation,” and a fishpond, not being cultivated land, is excluded from its coverage and the CAR’s jurisdiction. The Supreme Court rejected this argument. The Court held that Section 46(c) of Republic Act No. 1199 , as amended, explicitly provides that “the consideration for the use of… fishponds… shall be governed by stipulation between the parties.” This clear statutory inclusion of fishponds within the law’s ambit negates the claim of exclusion. The law does not require actual cultivation for a landholding to be subject to tenancy relations under its provisions.
Furthermore, the Court cited jurisprudence classifying land used for fish production as agricultural land. Since the respondents’ complaint was essentially for unlawful dispossession from their fishpond holding—a cause of action provided under Sections 27, 49, and 50 of Republic Act No. 1199 —the CAR possessed exclusive original jurisdiction. The petitioners’ additional arguments that the CAR lost jurisdiction because they had been in possession for two years prior to the complaint, or that the action was filed three years after dispossession, were also dismissed. Jurisdiction over the subject matter is determined by the allegations of the complaint and the law, not by possession timelines. The Agricultural Tenancy Act does not prescribe a period for filing a complaint for unlawful dispossession. Therefore, the CAR’s judgment was valid. The petition for certiorari was denied.