Don Pepe Henson Enterprises v. Pangilinan
REITERATIONFacts
The Antecedents: Private respondents filed an action for injunction against petitioners, praying to be restrained from disturbing their peaceful possession of landholdings they were tilling as tenants. Petitioners had allegedly fenced the areas and prohibited private respondents from entering the premises. Petitioners Don Pepe Henson Enterprises owned approximately 360 hectares of land, managed by Vicente Henson. In 1966, they leased the agricultural portion to Faustino Ocampo on a year-to-year basis, with the lessor retaining the right to terminate the lease for subdivision purposes upon six months' notice. Prior to this lease, 61 tenants were paid disturbance compensation for voluntary surrender of their landholdings; two of these, Mariano David and Juan Pangilinan (private respondents), received compensation and executed documents of surrender for lands different from those they now claim as tenants. Private respondents were allowed by Ocampo to till their respective parcels for a fee. Ocampo died in January 1972, and his son Pepito continued gathering crops until the lands were surrendered back to petitioners in 1972. Petitioners claim private respondents pleaded to continue farming, which they assented to in an agreement in January 1972. However, petitioners leased the lands to Augusta Ayson on November 20, 1972. When petitioners attempted to evict private respondents to develop the area for subdivision and resort purposes, private respondents filed the injunction case. Procedural History: The Court of Agrarian Relations (CAR) issued a temporary restraining order in favor of private respondents. Subsequently, the CAR rendered judgment finding private respondents to be lawful leasehold tenants entitled to security of tenure. Petitioners appealed to the Court of Appeals (CA), which affirmed the CAR decision in toto, holding that a leasehold tenancy relationship existed based on the evidence. The Petition: Petitioners seek review of the CA decision, disputing the sufficiency of the evidence and asserting that the CA should have made its own findings of fact, not merely relied on the trial court's.
Issue(s)
Whether the Court of Appeals erred in affirming the findings of fact of the trial court. Whether private respondents are lawful agricultural leasehold tenants entitled to security of tenure. Whether the leasehold tenancy relationship was extinguished by the expiration of the lease contract between petitioners and Faustino Ocampo, or by the subsequent lease to Augusta Ayson.
Ruling
The petition is denied. The appealed decision of the Court of Appeals dated June 6, 1980, is affirmed. The decision is immediately executory.
Ratio Decidendi
On the alleged error of the Court of Appeals in affirming the findings of fact of the trial court: The Supreme Court found no reversible error in the Court of Appeals' affirmation of the trial court's findings of fact. The Court reiterated that it is not the function of the Supreme Court to re-examine the evidence presented by the parties, particularly when the findings of fact of the trial court have been affirmed by the appellate court. The Court emphasized that the evidence adduced in the trial court sufficiently established the leasehold tenancy relationship between the petitioners and the private respondents. Petitioners' assertion that they were unwilling lessors and that the lease contract should be disregarded was deemed inconsistent with their argument that Ocampo violated the same contract by subleasing portions of the land. The Court found substantial evidence supporting the private respondents' status as tenants of Faustino Ocampo. On whether private respondents are lawful agricultural leasehold tenants entitled to security of tenure: The Supreme Court upheld the findings of both the Court of Agrarian Relations and the Court of Appeals that private respondents are entitled to security of tenure. The Court noted that Faustino Ocampo was the civil law lessee of the landholding when the private respondents were allowed to work on it, establishing a tenancy relationship. Even if some private respondents had previously received disturbance compensation for different landholdings, their subsequent engagement as tenants under Ocampo created a new tenancy relationship. The Court also pointed out that private respondents were listed as farmer beneficiaries of the government's Land Transfer program, which further supported their claim of tenancy. On whether the leasehold tenancy relationship was extinguished by the expiration of the lease contract or subsequent lease: The Supreme Court ruled that the agricultural leasehold relation is not extinguished by the mere expiration of the term or period in a leasehold contract, nor by the sale, alienation, or transfer of the legal possession of the landholding. Citing Section 10 of Republic Act No. 3844 (Agricultural Land Reform Code), the Court held that the purchaser or transferee is subrogated to the rights and substituted to the obligations of the agricultural lessor. The Court applied the principle that any doubt must be resolved in favor of the tenant. Furthermore, the Court found that even if Faustino Ocampo had breached his contract with petitioners by subleasing, the private respondents, not being parties to that contract, were still entitled to recognition as tenants. The Court also found that alleged relinquishments of possession by private respondents could not be enforced as they would contravene the security of tenure provisions.
Main Doctrine
The agricultural leasehold relation is not extinguished by the mere expiration of the term or period in a leasehold contract nor by the sale, alienation or transfer of the legal possession of the landholding. The purchaser or transferee shall be subrogated to the rights and substituted to the obligations of the agricultural lessor.