G.R. No. L-59082; June 28, 1991
DOMINGO SALEN and ROSA SALEN, petitioners, vs. HON. PEDRO M. DINGLASAN, JUDGE OF THE COURT OF AGRARIAN RELATIONS OF CAMARINES NORTE, JUANITO SEVILLA and BENITA SEVILLA, respondents.

FACTS

Petitioners Domingo and Rosa Salen owned agricultural land. On August 21, 1973, they executed a “Deed of Pacto de Retro” over the land in favor of Marietta A. San Buenaventura to secure a P5,000 loan. The vendee a retro, through an administratrix, employed private respondents Juanito and Benita Sevilla as tenant-tillers, who received a share of the produce. In June 1977, petitioners entered the land, harvested coconuts, and cultivated the riceland, ousting the Sevillas. The Sevillas filed an action for recovery of possession with the Department of Agrarian Reform (DAR), which ruled in their favor, recommending reinstatement as the repurchase would not terminate tenancy rights. The Sevillas then filed an illegal ejectment case with the Court of Agrarian Relations (CAR).

ISSUE

The primary issue is whether the tenancy relationship established by the vendee a retro was extinguished upon the petitioners’ repurchase of the landholding, thereby justifying the petitioners’ ejectment of the private respondents.

RULING

The Supreme Court affirmed the CAR decision, ruling that the tenancy relationship was not severed by the repurchase. The legal logic is anchored on the protective mantle of agrarian laws, specifically the principle of security of tenure for agricultural tenants. The Court applied Section 49 of Republic Act No. 1199 (The Agricultural Tenancy Act), which aims to prevent unjust dispossession. Upon repurchase, the petitioners stepped into the shoes of the previous landholder (the vendee a retro), inheriting the existing tenancy relationship with the Sevillas. The axiomatic principle “once a tenant, always a tenant” was invoked, emphasizing that the tenancy status, once lawfully established, persists despite changes in land ownership. This doctrine is rooted in the constitutional objective of social justice and the state’s police power to promote the common welfare. The Court further noted that the redemption occurred after the DAR ejectment judgment had become final, reinforcing the continuity of the tenancy. Consequently, the petitioners’ act of ousting the tenants was illegal, and the Sevillas were entitled to reinstatement, damages, and the application of leasehold provisions under agrarian reform laws.