GR L 18431; (June, 1962) (Digest)
G.R. No. L-18431; June 30, 1962
RUPINO ALARCON, ET AL., petitioners, vs. PILAR SANTOS, ET AL., respondents.
FACTS
Petitioners Rufino Alarcon, et al., filed a petition for reinstatement and damages before the Court of Agrarian Relations. They alleged they were tenants on land owned by respondent Pilar Santos but leased to Dionisio Alarcon, who employed them. Upon the termination of the lease contract, they were forcibly ejected by Pilar Santos. Respondent Santos denied the material allegations, asserting her rights as owner and counterclaiming for damages.
The agrarian court dismissed the petition for lack of jurisdiction. It found that the land was indeed owned by Santos but leased to Dionisio Alarcon, who employed the petitioners. Since Dionisio Alarcon was not impleaded as a respondent, the court concluded no tenancy relationship existed directly between petitioners and respondent Santos. It held it could only take cognizance of cases between landholders and tenants.
ISSUE
Whether the Court of Agrarian Relations has jurisdiction over an action for reinstatement filed by tenants against the landowner, where the tenants were originally employed by the landowner’s lessee.
RULING
Yes. The agrarian court committed reversible error in dismissing the case for lack of jurisdiction. Its ruling was a clear infringement of Section 9 of Republic Act No. 1199 (The Agricultural Tenancy Act). The law explicitly provides that the sale or alienation of the land does not of itself extinguish the tenancy relationship. Crucially, it mandates that “the purchaser or transferee shall assume the rights and obligations of the former landholder in relation to the tenant.”
Applying this provision by analogy, the termination of a lease and the reversion of possession to the landowner operates similarly to a “transfer” of managerial authority. The landowner steps into the shoes of the former landholder-lessee. Consequently, respondent Pilar Santos, as the owner who resumed possession, assumed the obligations of the lessee, Dionisio Alarcon, towards the petitioners. The tenancy relationship was not severed merely by the lease’s expiration.
Therefore, an action for reinstatement arising from the owner’s dispossession of the tenants falls squarely within the exclusive original jurisdiction of the Court of Agrarian Relations under Section 21 of the same Act. The case involves a dispute arising from the relationship of landholder and tenant. The lower court’s orders were set aside, and the case was remanded for further proceedings on the merits.