G.R. No. L-18225; June 30, 1964
MANUEL CAMUS and RAFAEL CAMUS, petitioners, vs. COURT OF AGRARIAN RELATIONS, TIBURCIO HILARIO, ET AL., VICENTE PASCUAL, RUFINO DE LA CRUZ, ET AL., respondents.

FACTS

Respondents Tiburcio Hilario, et al., filed a petition in the Court of Agrarian Relations against petitioners Manuel and Rafael Camus. They alleged that in 1949, they were engaged as tenants by the Camuses to work, excavate, and convert the petitioners’ fishpond in Sagay, Occidental Negros, into saltbeds. The agreement stipulated that the petitioners would defray the expenses for the conversion, and thereafter, the salt produce would be divided equally between the parties. Respondents claimed they successfully made 485 parcels of saltbeds but were subsequently ejected as tenants between 1955 and 1957. They prayed for liquidation and accounting of the salt produce from 1949 to 1957, payment of their half share, reinstatement, damages, and attorney’s fees.
Petitioners moved to dismiss the case on the ground that the Court of Agrarian Relations lacked jurisdiction. They contended the relationship did not involve tenancy of agricultural land, as salt production is not an agricultural process. The respondent court denied the motion to dismiss and the subsequent motion for reconsideration. This prompted the petitioners to file the instant petition for review by certiorari, with a preliminary injunction granted by the Supreme Court to halt proceedings below.

ISSUE

Whether the Court of Agrarian Relations has jurisdiction over the dispute, which hinges on whether the relationship between the parties, involving land converted from a fishpond to saltbeds, constitutes agricultural tenancy under the law.

RULING

The Supreme Court ruled affirmatively, holding that the Court of Agrarian Relations has jurisdiction. The legal logic proceeds from the statutory framework governing agrarian relations. The Court first examined Republic Act No. 1267 , as amended, which created the Court of Agrarian Relations and granted it jurisdiction over relationships involving the cultivation and use of agricultural land where one party works the land. The land in question was originally an agricultural fishpond. The Court rejected the petitioners’ argument that its conversion to saltbeds altered its fundamental agricultural character, noting that the physical land serves merely as an evaporating basin in salt production and such use does not reclassify it as mineral land under the Mining Act.
Crucially, the Court found that the jurisdiction under the law encompasses not only “cultivation” but also the “use” of agricultural land. More definitively, the Court resolved any doubt by referencing the specific provisions of the Agricultural Tenancy Act ( Republic Act No. 1199 ). Section 46 of this Act, which governs leasehold tenancy considerations, explicitly classifies and mentions “saltbeds” alongside sugar lands and fishponds, indicating that stipulations between parties govern their use. This inclusion was reaffirmed in the subsequent Agricultural Land Reform Code ( Republic Act No. 3844 ). These explicit statutory references demonstrate the clear legislative intent to include saltbed operations within the purview of tenancy laws and, consequently, under the jurisdiction of the Court of Agrarian Relations. Therefore, the disputed relationship falls within its jurisdictional ambit. The Court affirmed the questioned orders, dissolved the preliminary injunction, and remanded the case for further proceedings.