G.R. No. 72282, July 24, 1989
Anacleto de Jesus, petitioner, vs. Hon. Intermediate Appellate Court, Socorro Calimbas-Miaco, Guillermo Calimbas-Rodriguez and Tirso Calimbas, respondents.

FACTS

Private respondents, as heirs, owned a fishpond in Pilar, Bataan. Petitioner Anacleto de Jesus had possessed the fishpond since 1962. On April 22, 1972, the parties executed a civil law lease contract effective for two and a half years, from January 1, 1972, to July 1, 1974. Petitioner and a capitalist partner, Felicisima Rodriguez, formed a partnership to operate the fishpond. Upon the contract’s expiration in 1974, Rodriguez gave up the lease, but petitioner refused to vacate. Private respondents filed an action for recovery of possession with damages before the Court of First Instance (CFI).
The CFI dismissed the complaint for lack of jurisdiction, ruling petitioner was an agricultural lessee under the Tenancy Law, thus jurisdiction belonged to the Court of Agrarian Relations. The CFI based this on findings that the land was agricultural, that petitioner managed the fishpond alone after 1974, and on a motu proprio ocular inspection showing petitioner was the sole worker. The Intermediate Appellate Court initially affirmed this dismissal.

ISSUE

The pivotal issue is whether petitioner is an agricultural lessee entitled to security of tenure under tenancy laws or merely a civil law lessee whose right terminated upon the contract’s expiration.

RULING

The Supreme Court affirmed the appellate court’s reconsidered resolution, ruling petitioner is a civil law lessee, not an agricultural lessee. The legal logic hinges on the statutory definition and essential elements of agricultural leasehold. Under the Agricultural Land Reform Code, an agricultural lessee is one who cultivates the land by himself and with the aid available from within his immediate farm household. Personal cultivation is a fundamental requisite.
The Court found petitioner failed to meet this criterion. The evidence, including petitioner’s own judicial admissions, established that he did not personally cultivate the fishpond nor rely on his immediate farm household. Instead, he hired numerous outside laborers to work on the land. Furthermore, he admitted to cultivating an adjacent 11.5-hectare fishpond, indicating he operated as a business entrepreneur in the fishpond industry, not as a small farmer. These facts disqualified him from being an agricultural lessee under the doctrine in Gabriel v. Pangilinan. Consequently, the civil law lease contract governed the relationship, and his right to possess the land lawfully terminated on July 1, 1974. The Court also noted that the jurisdictional issue was rendered moot by Batas Pambansa Blg. 129, which vested agrarian cases within the jurisdiction of the Regional Trial Courts. The civil lease contract was upheld as valid and enforceable.