De Jesus v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: Private respondents are owners of a 7.162-hectare land in Pilar, Bataan, which includes a fishpond. Petitioner Anacleto de Jesus had been in possession of about four hectares of this land as a lessee since 1962. On April 22, 1972, a civil law contract of lease was entered into between the heirs of the owners and petitioner de Jesus along with Felicisima Rodriguez, for a term of 2-1/2 years, from January 1, 1972, to July 1, 1974. Petitioner and Rodriguez formed a partnership for the fishpond, with de Jesus as industrial partner and Rodriguez as capitalist. Upon expiration of the lease on July 1, 1974, Rodriguez relinquished her interest, but petitioner refused to vacate despite demands. Procedural History: Private respondents filed a complaint for Recovery of Possession with Damages before the Court of First Instance (CFI) of Bataan. The CFI dismissed the case for lack of jurisdiction, ruling that the fishpond was agricultural land and petitioner was an agricultural lessee, thus falling under the jurisdiction of the Court of Agrarian Relations. The CFI based this on the land being agricultural, Felicisima Rodriguez's testimony that petitioner managed it alone after 1974, and the judge's observation of petitioner working alone. The Intermediate Appellate Court (IAC) initially affirmed the CFI's decision. However, upon motion for reconsideration, the IAC reversed its earlier ruling, holding that petitioner was a civil law lessee, not an agricultural lessee, and ordered him to vacate. The IAC's reversal was based on stronger evidence, including petitioner's admission that he hired many people to cultivate the land, disqualifying him as an agricultural lessee under Republic Act No. 3844 and the doctrine in Gabriel v. Pangilinan. Petitioner's motion for reconsideration of the IAC's reversed decision was denied. The Petition: Petitioner filed a petition for review on certiorari with the Supreme Court, assailing the IAC's resolution for being unsupported by evidence, inconclusive, and contrary to law and jurisprudence.
Issue(s)
Whether petitioner Anacleto de Jesus is an agricultural lessee or a civil law lessee. Whether the Court of First Instance had jurisdiction over the case.
Ruling
The Supreme Court affirmed the Resolution of the Intermediate Appellate Court, ordering petitioner to vacate the premises, pay rentals, attorney's fees, and litigation expenses.
Ratio Decidendi
On the issue of whether petitioner is an agricultural lessee or a civil law lessee: The Court ruled that petitioner is not an agricultural lessee. While a fishpond may be considered agricultural land, this fact alone does not automatically qualify one as an agricultural lessee. The Agricultural Land Reform Code requires specific conditions, including personal cultivation by the lessee and their immediate farm household. Petitioner's own judicial admission that he hired many people to cultivate the fishpond, including his sons and father-in-law, contradicted the claim of personal cultivation. Furthermore, his admission of cultivating an adjacent 11-1/2 hectare fishpond, employing numerous laborers, established him as a businessman rather than a small farmer, which is the intended beneficiary of the Agricultural Land Reform Code. The Court emphasized that the law's intent is to uplift small farmers, and extending its benefits to a businessman operating on a large scale would render the law nugatory. The case of Evangelista v. Court of Appeals was cited, holding that one is not an agricultural lessee if the land is not personally cultivated or cultivated with the aid of the farm household. The Court also noted that petitioner's claim of vitiated consent regarding the civil law lease contract was an insufficient ground to make the contract unenforceable, as it only rendered it voidable, requiring annulment. On the issue of jurisdiction: The Court held that the issue of jurisdiction of the Court of First Instance has become moot and academic due to the passage of Batas Pambansa Blg. 129 (The Judiciary Reorganization Act of 1980). Section 19 of BP 129 grants Regional Trial Courts (formerly Courts of First Instance) jurisdiction over cases previously cognizable by the Court of Agrarian Relations.
Main Doctrine
A fishpond operator who hires numerous laborers for cultivation and operates a large adjacent fishpond is considered a businessman and not an agricultural lessee entitled to security of tenure under the Agricultural Land Reform Code, as the latter requires personal cultivation by the lessee or their immediate farm household.