G.R. No. 88113 October 23, 1992
SPOUSES TITUS L. ENDAYA and GLENDA TRINIDAD; SPOUSES RICO L. ENDAYA and NANETTE AQUINO; and SPOUSES JOSEPHINE L. ENDAYA and LEANDRO BANTUG, petitioners, vs. COURT OF APPEALS and PEDRO FIDELI, respondents.

FACTS

The Spouses Natividad Trinidad and Cesar San Diego owned a 20,200-square-meter agricultural land in San Pioquinto, Malvar, Batangas, devoted to rice and corn. Since 1934, private respondent Pedro Fideli had been cultivating this land as a tenant of the Spouses San Diego under a fifty-fifty (50-50) sharing agreement, a fact undisputed by petitioners. On May 2, 1974, the Spouses San Diego executed a four-year civil lease contract with Regino Cassanova, obliging Cassanova to pay P400.00 per hectare per annum and giving him authority to oversee the planting of crops. Private respondent signed this contract as a witness. The lease was later renewed until May 1980, with the rental increased to P600.00, and private respondent again signed as a witness. During the entire duration of the civil lease, private respondent continuously cultivated the land, sharing equally the net produce with Cassanova. On January 6, 1980, the Spouses San Diego sold the land to petitioners. Private respondent continued to farm the land and deposited about P8,000.00 with the Luzon Development Bank as partial payment of the landowner’s share for the years 1980 to 1985. Due to petitioners’ persistent demands to vacate, private respondent filed a complaint in April 1985 with the Regional Trial Court (RTC) of Tanauan, Batangas, praying to be declared the agricultural tenant of petitioners. The RTC dismissed the complaint and ordered private respondent to vacate. On appeal, the Court of Appeals reversed the RTC and declared private respondent to be the agricultural lessee.

ISSUE

Whether the civil lease contract between the original landowners (Spouses San Diego) and Regino Cassanova extinguished the agricultural leasehold relationship between the landowners and private respondent Pedro Fideli, thereby negating his status as an agricultural lessee entitled to security of tenure against the subsequent purchasers (petitioners).

RULING

No. The Court of Appeals’ decision is affirmed. Private respondent Pedro Fideli is an agricultural lessee entitled to security of tenure. The agricultural leasehold relation, once established, is not extinguished by the mere execution of a civil lease contract over the same landholding. Republic Act No. 3844, as amended, abolished share tenancy and established the agricultural leasehold system by operation of law, conferring upon the agricultural lessee the right to security of tenure. Section 10 of the law explicitly provides that the agricultural leasehold relation shall not be extinguished by the sale, alienation, or transfer of the legal possession of the landholding. In case of such transfer, the purchaser or transferee is subrogated to the rights and substituted to the obligations of the agricultural lessor. The civil lease contract to Cassanova constituted a transfer of legal possession, but it did not terminate Fideli’s agricultural leasehold rights. His consent as a witness to the lease contracts did not constitute a waiver of his rights. The continuous cultivation of the land by Fideli, sharing the harvest with Cassanova, further strengthened his security of tenure. Therefore, petitioners, as successors-in-interest, are subrogated to the obligations of the original landowners and must respect Fideli’s rights as an agricultural lessee.