G.R. No. L-29381 September 30, 1969
PHILIPPINE NATIONAL RAILWAYS and PANTALEON BINGABING, petitioners, vs. HON. VALERIANO A. DEL VALLE, in his capacity as Presiding Judge, Court of Agrarian Relations and PAMPILO DOLTZ, respondents

FACTS

The Philippine National Railways (PNR), a government-owned corporation, is the registered owner of three strips of land (30 meters wide) within its railroad right of way in Albay. At the center is a 10-12 meter wide track for trains. On both sides are telegraph/telephone posts, and PNR uses these areas to source earth for track repairs and to store materials. Due to disputes from unauthorized occupation, PNR adopted temporary leasing rules: award by public bidding, lease not exceeding three years, non-sublease, revocable if PNR needs the land, PNR’s right to enter for repairs, and use not prejudicial to operations. In 1963, PNR awarded the lease to Pantaleon Bingabing via a civil law lease contract stating the property was “to occupy and use the property … temporarily for agriculture.” Bingabing could not take possession because respondent Pampilo Doltz was occupying the land, claiming to be a tenant of previous awardees and later of Bingabing himself. PNR and Bingabing filed a recovery of possession case against Doltz in the Court of First Instance of Albay (Civil Case 3021). While that case was pending, Doltz filed a petition in the Court of Agrarian Relations (CAR) against Bingabing for security of tenure and crop sharing. PNR intervened. The CAR upheld its jurisdiction, maintained Doltz as a tenant, and ordered a 70-30 sharing ratio in his favor. Petitioners challenged the CAR’s jurisdiction.

ISSUE

Whether or not strips of land owned by PNR which are on both sides of its railroad track, and are part of its right of way but temporarily leased, are agricultural lands within the purview of the Agricultural Tenancy Act and the Agricultural Land Reform Code, such as would come within the jurisdiction of the Court of Agrarian Relations.

RULING

No. The Supreme Court reversed the decision of the Court of Agrarian Relations and dismissed the case. The land in controversy is not agricultural land under the relevant tenancy laws. The entire 30-meter width is part of PNR’s right of way essential for safe railroad operations, providing a clear view, housing communication lines, and serving as a source of materials and space for repairs. Its use is inconsistent with agricultural activities due to PNR’s right to enter, place materials, take soil, and potentially construct additional tracks. The civil law lease contract with Bingabing was temporary and revocable, expressly distinguished from an agricultural lease by law. Furthermore, PNR prohibited sublease; thus, any subletting to Doltz without PNR’s consent was invalid and could not create a tenancy relationship. Doltz could not be considered a tenant de jure. Therefore, the CAR had no jurisdiction over the case.