G.R. No. L-28227. July 11, 1973.
FELICIANO YABUT, ET AL., plaintiffs-appellants, vs. REMEGIO LILLES, defendant-appellee.

FACTS

The appellants were agricultural tenants on riceland owned by Graciana Miranda Vda. de Lilles. In 1956, the landowner secured judicial authority from the Court of Agrarian Relations (CAR) in CAR Case No. 155-P ’56 to convert the land back into a fishpond, a use for which it was deemed more suitable, and to eject the tenants. The 1957 CAR decision authorized reconversion within three years, with a proviso that the tenants would be reinstated with damages if the conversion was not completed. The judgment became final; a writ of execution issued in 1958. The tenants vacated after receiving monetary compensation. The land was excavated and fully converted into an operational fishpond within five months, well within the three-year period. The landowner complied with the order to give preference to the ejected tenants for fishpond labor, but only two accepted. The property’s tax assessment increased substantially, confirming its use as a fishpond.
Years later, in the 1965-1966 agricultural year, the new owner, Remegio Lilles (the landowner’s successor), began experimenting with planting palay on portions of the land, eventually expanding to 25 hectares by 1966-1967. Claiming this constituted a reconversion to agricultural use, the former tenants filed CAR Case No. 474-P ’67 seeking reinstatement as tenants. The CAR dismissed the complaint for lack of jurisdiction, ruling that the tenancy relationship had been lawfully terminated.

ISSUE

Whether the Court of Agrarian Relations retained jurisdiction over the appellants’ action for reinstatement, or whether the prior final judgment of ejectment and the subsequent events had extinguished the tenancy relationship.

RULING

The Supreme Court affirmed the dismissal, holding that the CAR correctly found it lacked jurisdiction due to the absence of a tenancy relationship. The legal logic is clear: a tenancy relationship can be lawfully terminated by a final and executory judgment of ejectment for a cause provided by law, such as authorized land conversion. The 1957 CAR decision was precisely such a final judgment. The tenants’ compliance—vacating the land and accepting compensation—constituted voluntary surrender and abandonment of their landholding, which are additional modes of extinguishing tenancy under the Agricultural Tenancy Act. The condition in the 1957 decision for possible reinstatement was a resolutory one, contingent on the landowner’s failure to convert the land within three years. This condition did not occur, as the conversion was completed promptly and the land was operated as a fishpond for years. The subsequent planting of palay by the new owner did not automatically revive the old tenancy relationship. With the juridical tie lawfully severed, the former tenants had no standing to seek reinstatement. Their remedy, if any, would be to establish a new tenancy relationship through a new contract, not to resurrect an extinguished one. Consequently, no tenancy issue existed for the CAR to adjudicate, warranting dismissal for lack of jurisdiction.