G.R. No. L-10594; May 29, 1957
PONCIANO PRIMERO, petitioner, vs. COURT OF AGRARIAN RELATIONS and SINFOROSO QUION, respondents.

FACTS

Petitioner Ponciano Primero is the owner of a riceland in Cavite, with respondent Sinforoso Quion as his tenant. On March 3, 1956, Primero served a written notice to Quion to vacate the land because Primero desired to lease it to Porfirio Potente for the purpose of converting it into a “zacatal” (a field for growing “zacate,” a species of grass for horse feed). Quion refused to vacate. Primero executed a lease contract with Potente on March 7, 1956, but Quion’s continued presence hindered delivery of the land to the lessee. Primero filed a petition with the Court of Agrarian Relations seeking an order to direct Quion to vacate. Quion moved to dismiss the petition, arguing it stated no cause of action as the lease and intended conversion were not among the statutory causes for dispossessing a tenant under Republic Act No. 1199 (the Agricultural Tenancy Act). The agrarian court granted the motion and dismissed the petition. Primero appealed, contending he had the right to dispossess his tenant to lease the land for conversion to zacatal, that the lessee had the right to employ a worker of his choice, and that zacate is not an agricultural produce under the Act.

ISSUE

Whether, under the facts stated, the landowner has the right to eject his tenant from the riceland solely because the land was leased to a third person who intends to convert it into a zacatal.

RULING

The Supreme Court affirmed the order of dismissal from the Court of Agrarian Relations. The Court held that under Sections 9, 49, and 50 of Republic Act No. 1199 , the lease of the land did not of itself extinguish the tenancy relationship between Primero and Quion. Under Section 9, the lessee (Potente) would assume the rights and obligations of the former landholder (Primero) in relation to the tenant (Quion). Furthermore, Section 49 provides that a tenant shall not be dispossessed except for causes enumerated in Section 50, and the lease of the land for conversion to zacatal is not one of those enumerated causes. The Court also rejected the constitutional challenge, stating that the assailed provisions do not impair the landowner’s right to alienate property but merely preserve the tenancy relationship upon transfer to protect the tenant’s security of tenure, in line with the social justice mandates of the Constitution and the state’s police power. The Court found it unnecessary to rule on whether zacate is an agricultural product, as the core issue was the legality of the dispossession.