G.R. No. L-27670 December 27, 1969
MANILA RAILROAD COMPANY (PNR), petitioner, vs. THE COURT OF APPEALS, AMBROCIO PINEDA, respondents.

FACTS

The case originated from the Court of Agrarian Relations (CAR). Respondent Ambrocio Pineda filed an action to compel the Manila Railroad Company (now PNR) and Mariano Mendoza to recognize him as a tenant on a strip of land 30 meters wide in San Mateo, Sto. Tomas, Pampanga, which is part of the petitioner’s railroad right-of-way. Pineda claimed to have worked the land for 25 years under a share tenancy arrangement with successive lessees of the PNR. After the lease of the prior lessee, Maria Canlas, expired, Mariano Mendoza became the new lessee. Pineda objected to Mendoza’s entry, leading Mendoza to sue Pineda in the CAR. Pineda remained in possession under a CAR order and planted palay for the 1960-1961 agricultural year. The PNR also filed a forcible entry case against Pineda, which was dismissed. After Pineda threshed the palay, the PNR demanded and received a rental deposit. Pineda then filed the present CAR action to be recognized as an agricultural tenant and to convert the tenancy from share to leasehold. The CAR ruled in favor of Pineda, maintaining him as an agricultural tenant of the PNR, converting the tenancy to leasehold, and fixing an annual rental. The Court of Appeals affirmed this decision. The PNR petitioned for review, arguing the CAR lacked jurisdiction because the land is not agricultural land under relevant tenancy laws.

ISSUE

Whether or not the Court of Agrarian Relations had jurisdiction over the case, specifically, whether the strip of land forming part of the railroad right-of-way is “agricultural land” within the purview of the Agricultural Tenancy Act (Republic Act No. 1199) and the Agricultural Land Reform Code (Republic Act No. 3844).

RULING

The Supreme Court reversed the decision of the Court of Appeals and dismissed the case. The Court held that the Court of Agrarian Relations had no jurisdiction. The land in question, being part of the PNR’s railroad right-of-way, is not “agricultural land” as defined under the Agricultural Tenancy Act and the Agricultural Land Reform Code. The PNR, by its charter (Republic Act 4156), is not authorized to engage in agricultural production. The land’s primary purpose is for railroad operations, including providing a clear view for engineers, placing communication lines, and allowing for repairs and construction. This use is inconsistent with agricultural activities and the security of tenure required in landlord-tenant relationships. Therefore, the land, by its legal destination, is not agricultural, and the tenancy laws do not apply.