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, in partnership with Felicisima Rodriguez, entered into a civil law lease contract for the fishpond effective from January 1, 1972, to July 1, 1974. Upon the contract’s expiration, Rodriguez relinquished her interest, but de Jesus 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 case for lack of jurisdiction, ruling that the fishpond was agricultural land and that de Jesus, by personally managing it after 1974, had become an agricultural lessee under the Tenancy Law, thereby placing jurisdiction with the Court of Agrarian Relations. The Intermediate Appellate Court initially affirmed this dismissal.

ISSUE

The pivotal issue is whether petitioner Anacleto de Jesus is an agricultural lessee, entitled to security of tenure under agrarian laws, or merely a civil law lessee whose rights terminated with the lease contract.

RULING

The Supreme Court ruled that de Jesus is a civil law lessee, not an agricultural lessee. The legal logic hinges on the statutory definition of an “agricultural lessee” under the Agricultural Land Reform Code (RA 3844), which requires cultivation “by himself and with the aid available from within his immediate farm household.” The Court found that de Jesus did not meet this criterion. He admitted to hiring laborers outside his immediate family to work on the subject fishpond. Furthermore, he was cultivating an adjacent 11.5-hectare fishpond, indicating he operated as a business entrepreneur in the fishpond industry, not as a small farmer whom the agrarian laws were designed to protect.
Consequently, his tenancy relationship was governed by the civil law lease contract, which expressly expired on July 1, 1974. His refusal to vacate thereafter constituted unlawful detainer. The Court also noted that the jurisdictional issue was rendered moot by Batas Pambansa Blg. 129, which vested Regional Trial Courts (successors to the CFI) with jurisdiction over cases previously cognizable by the Court of Agrarian Relations. Therefore, the CFI had jurisdiction to hear the ejectment case. The Supreme Court affirmed the appellate court’s resolution ordering de Jesus to vacate the land and pay rentals and damages.