G.R. No. 171346; October 19, 2007
JAIME SANCHEZ, JR., Petitioner, vs. ZENAIDA F. MARIN, JESUS NICASIO F. MARIN, JOSE DAVID F. MARIN, MARIA BERNADETTE F. MARIN, PAUL PETER F. MARIN and PHILIP LUIS F. MARIN, Respondents.

FACTS

Petitioner Jaime Sanchez, Jr. was instituted as an agricultural tenant on a 10-hectare fishpond in 1977 by the then-owner, David Felix, under a 50/50 sharing agreement. The fishpond was later sold to the Marin respondents. In 1985, respondent Zenaida F. Marin, as civil law lessee of her children (the new owners), entered into an arrangement with Sanchez wherein he would receive a salary and a 20% share of net profits until June 1986. After this period, Zenaida ordered Sanchez to vacate. Sanchez refused, asserting his status as a tenant with security of tenure. This led to a prior case where the RTC and subsequently the Court of Appeals definitively declared Sanchez as an agricultural tenant of the fishpond, a decision which became final and executory.
Subsequently, Sanchez filed a petition to fix leasehold rentals. The Marin respondents, while admitting his tenancy status, filed a complaint for his ejectment due to alleged non-payment of rentals from 1987 to 1991. Sanchez countered that he had no harvests during some periods due to the respondents’ refusal to advance production expenses and that he had deposited rentals with the court, which Zenaida withdrew. The Provincial Agrarian Reform Adjudicator (PARAD) ruled in favor of Sanchez, but the Department of Agrarian Reform Adjudication Board (DARAB) reversed, ordering Sanchez to pay rental arrears and vacate the land. The Court of Appeals then annulled the DARAB decision, reinstating the PARAD’s ruling but remanding the case for proper fixing of rentals.

ISSUE

The core issue is whether the petitioner, as a duly declared agricultural tenant, can be ejected from the fishpond for alleged non-payment of leasehold rentals.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic hinges on the application of agrarian laws and the principle of security of tenure. The Court emphasized that the petitioner’s status as an agricultural tenant was already settled with finality in prior litigation. Under Section 7 of Republic Act No. 1199 (The Agricultural Tenancy Act), a tenancy relationship, once established, entitles the tenant to security of tenure. Ejectment can only occur for grounds specifically provided by law.
The Court found that the alleged non-payment of rentals was not a valid ground for ejectment under the circumstances. The obligation of a tenant to pay lease rental is dependent on there being an actual harvest. The petitioner sufficiently established that there were no harvests during certain periods due to the landholder’s failure to contribute production expenses, which excuses non-payment. Furthermore, the petitioner’s consignation of rentals with the court, which were withdrawn by the respondent, constitutes valid payment. Therefore, the respondents failed to prove a lawful cause for ejectment. The case was remanded solely for the ministerial act of fixing the appropriate leasehold rental, as the tenancy relationship and the tenant’s right to remain on the land were upheld.