GR 164912; (June, 2008) (Digest)
G.R. No. 164912; June 18, 2008
PAG-ASA FISHPOND CORPORATION, petitioner, vs. BERNARDO JIMENEZ, ROBERT BELENBOUGH, LEONARD MIJARES, EDUARDO JIMENEZ, JOSE CRUZ, ELIZALDE EDQUIBAL, DOMINADOR ELGINCOLIN and GERONIMO DARILAG, respondents.
FACTS
Pag-asa Fishpond Corporation owned a 95-hectare fishpond and saltbed in Masinloc, Zambales. On May 1, 1989, it executed a five-year civil law lease contract over portions of the property with David Jimenez and Noel Hilario. The contract explicitly prohibited the lessees from sub-letting the property or assigning their rights. Upon the lease’s expiration on May 1, 1994, Pag-asa demanded that the lessees and their workers, the herein respondents, vacate the premises. The respondents, who were fishpond workers hired by the lessees and compensated with a share in the harvest, refused to leave, claiming they were tenants entitled to security of tenure under agrarian reform laws. Pag-asa filed an action for maintenance of peaceful possession before the DARAB.
ISSUE
Whether the respondents, who were farmworkers hired by the civil law lessee, acquire tenurial rights as agricultural tenants or leaseholders upon the expiration of the principal lease contract between the landowner and the lessee.
RULING
No. The Supreme Court ruled that the respondents did not acquire any tenurial rights that would allow them to remain on the land after the expiration of the principal lease. The legal logic is anchored on the principle of relativity of contracts and the nature of the respondents’ relationship with the landowner. The contract of lease between Pag-asa and Jimenez and Hilario was a civil law lease, not an agricultural leasehold under agrarian laws. The respondents were merely employees or sub-lessees of the civil law lessees. Their rights were therefore derivative and dependent entirely on the rights of their immediate employers, the lessees. When the five-year lease contract expired and was not renewed, the lessees’ right to possess the land ceased. Consequently, all rights derived from that lease, including the respondents’ permission to work on the land, also terminated. The Court emphasized that the respondents had no direct contractual relationship with the landowner, Pag-asa. Their arrangement was solely with the lessees. The prohibition against sub-letting in the main contract further negated any claim of a legitimate sub-lease that could bind the owner. Thus, upon the lease’s expiration, Pag-asa’s right to possess its property was restored, and the respondents had no legal basis to refuse vacating the land.