GR L 28643; (November, 1969) (Digest)
G.R. No. L-28643 November 28, 1969
CATALINO GAMALOG, ET AL., petitioners, vs. THE COURT OF APPEALS, ETC., ET AL., respondents.
FACTS
Petitioners were tenants of Lope Soriano, the former lessee of a land owned by Magdaleno Tinio. After the expiration of Soriano’s lease, Tinio entered into a new lease contract with the Hernandez brothers (Lorenzo and Roberto) on March 10, 1965. The Hernandez brothers filed a suit for recovery of possession against petitioners (Soriano’s tenants) in the Court of First Instance of Isabela when petitioners refused to vacate. The CFI issued a writ of preliminary mandatory injunction, allowing the Hernandez brothers to take possession and install their own tenants (private respondents) on the land. On February 20, 1967, the CFI dismissed the complaint for lack of jurisdiction, ruling the case involved tenancy disputes within the exclusive jurisdiction of the Court of Agrarian Relations (CAR). That CFI decision was pending appeal in the Court of Appeals. On March 29, 1967, petitioners filed a complaint with the CAR seeking immediate reinstatement. The CAR, on June 28, 1967, issued an order directing petitioners’ immediate reinstatement upon posting a bond. Private respondents then filed a certiorari proceeding with the Court of Appeals seeking to annul the CAR’s reinstatement order. The Court of Appeals set aside the CAR order and granted the writ of prohibition, relying on its reading of the Evangelista v. Court of Agrarian Relations doctrine.
ISSUE
Whether the Court of Appeals erred in setting aside the order of the Court of Agrarian Relations that directed the reinstatement of the petitioners (tenants of the former lessee) to the landholding.
RULING
Yes, the Court of Appeals erred. The Supreme Court reversed the decision of the Court of Appeals and revived the order of the Court of Agrarian Relations. The law is clear under Section 9 of Republic Act No. 1199 (Agricultural Tenancy Act), as amended, which provides that the expiration of a lease contract or the transfer of legal possession does not extinguish the tenancy relationship, and the purchaser or transferee (new lessee) shall assume the rights and obligations of the former landholder towards the tenant. The Court of Appeals had expressly admitted in its decision that petitioners were tenants of the former lessee, a relationship that must be respected by the new lessee. The Evangelista case relied upon by the Court of Appeals is distinguishable because there the existence of a tenancy relationship was in issue, whereas here it was categorically found to exist. Furthermore, the CFI had already dismissed the new lessee’s ejectment case for lack of jurisdiction, recognizing it as a tenancy dispute. The constitutional and statutory policy of social justice and protection to labor, particularly the security of tenure of tenants, mandates this ruling.