GR L 36654; (March 1987) (Digest)
G.R. No. L-36654 March 3, 1987
FRANCISCO NOVESTERAS, petitioner, vs. THE HON. COURT OF APPEALS and FABIO RAMOS, respondents.
FACTS
Petitioner Francisco Novesteras was originally a share tenant of respondent Fabio Ramos over two parcels of agricultural land. After one agricultural year, Ramos entered into a civil lease contract with Rosendo Porlucas. Porlucas did not personally cultivate the land; instead, he allowed Novesteras to till it as his tenant. Upon the expiration of Porlucas’s lease, Ramos and Novesteras directly entered into a series of written contracts denominated as contracts of “civil lease.” Under these agreements, Novesteras was to pay a fixed rental of 60 cavans of palay annually and was to personally cultivate the land. When Ramos later refused to renew the contract and took possession of the land, Novesteras filed an action in the Court of Agrarian Relations to maintain his peaceful possession.
ISSUE
The sole issue is whether an agricultural tenancy relationship was established between Novesteras and Ramos, thereby vesting jurisdiction in the agrarian court.
RULING
Yes, an agricultural leasehold tenancy relationship existed. The Supreme Court reversed the Court of Appeals and the Court of Agrarian Relations, which had erroneously classified the contracts as civil law leases. The Court emphasized that the legal nature of a contract is determined by its essential terms and the parties’ conduct, not merely by its title. For an agricultural leasehold tenancy to exist, the following elements must concur: (1) the object is an agricultural land leased for agricultural production; (2) the landholding is of a size cultivable by the tenant and his immediate household; (3) the tenant personally cultivates the land; and (4) the consideration is a fixed amount in money or produce.
All these elements were present. Novesteras, a farmer, leased the land specifically for agricultural production. He personally cultivated it, a fact corroborated by testimony. The consideration was a fixed rental of 60 cavans of palay. The contracts, though labeled “civil lease,” embodied the substance of an agricultural leasehold. Consequently, Novesteras was a de jure tenant-lessee entitled to security of tenure under agrarian laws. The agrarian court therefore had jurisdiction over the case. The contracts (Exhibits “6,” “7,” and “7-J”) were declared agricultural leasehold contracts.