G.R. No. L-12898; August 31, 1960
ESTANISLAO PABUSTAN, petitioner, vs. THE HON. PASTOR DE GUZMAN, ETC., ET AL., respondents.

FACTS

On September 20, 1955, Fidel Isip filed a petition (later amended) with the Court of Agrarian Relations for the ejectment of Cecilio Bautista and Estanislao Pabustan from a landholding. Isip alleged that tenant Cecilio Bautista sublet the property to Estanislao Pabustan without Isip’s knowledge and consent starting crop year 19541955, and that Pabustan failed to pay full agreed rentals for 19541955 and 19551956. After hearing, the respondent Judge held that Cecilio Bautista was the tenant from 1938 until April 1954, when he surrendered the land to Isip. The court found no need to eject Bautista, as he had already ceased to be a tenant. However, it ordered Estanislao Pabustan ejected and directed him to pay Isip 84 cavans of palay as rentals for three agricultural years (19541955 to 19561957), on the ground that Pabustan had been working the land from 19541955 without Isip’s knowledge and consent, making him a squatter or intruder.

ISSUE

Whether the Court of Agrarian Relations had jurisdiction over the case against Estanislao Pabustan, given the absence of a tenancy relationship between the parties.

RULING

The Supreme Court reversed the decision of the Court of Agrarian Relations. It held that the respondent court lacked jurisdiction because there was no tenancy relationship between the parties. The lower court itself ruled that Pabustan was an unlawful squatter or intruder, which negated any tenancy relationship essential for the court’s jurisdiction. The Court rejected Isip’s claim that Bautista sublet the land to Pabustan without consent, noting that the lower court found Bautista had surrendered the landholding in April 1954 and Isip accepted it. Since Bautista’s lease had already ceased, he could not have sublet the land. Consequently, the decision against Pabustan was set aside, with costs against respondent Fidel Isip.