Endaya v CA

Spouses Natividad and San Diego owned an agricultural land with 20,200
sq.m at San Pioquinto, Malvar, Batangas devoted to rice and corn.
1934 Fideli has been cultivating that land as tenant of Spouses San Diego
under 50-50 sharing agreement.
1974 Spouses San Diego and Cassonova entered into a lease contract for 4
years (May 1974-1978). Fideli signed as one of the two witnesses of that
contract.
The lease contract was renewed until May 1980 but the rental was raised
from 400 to 600php. Again, Fideli signed the contract as witness.
During the entire duration of the lease contract, Fideli continuously
cultivated the land, sharing equally with Cassanova the net produce of
the harvests.
Spouses San Diego then sold the land to Spouses Endaya and the sale was
registered with Register of Deeds.
But Fideli continued to farm even though Endaya told him to vacate.
Fideli then filed at RTC Batangas saying that he be declared the
agricultural tenant of petitioner. (DENIED)
CA reversed RTC decision saying that Fideli is an agricultural lessee.
Endaya appealed alleging that:
landowner cannot have a civil law lease contract w/ one person then have
an agricultural leasehold agreement with another over the same land
private respondent consented to the lease agreement b/w Spouses San
Diego and Cassanova by signing the lease agreement and renewal as a
witness of such contract, hence, Fideli waived his right as an agricultural
lessee.
ISSUE: W/N Fideli is an agricultural tenant of petitioner? YES
HELD:
RA 3844, established the agricultural leasehold system and abolished the share
tenancy.
Sec 8 gave agricultural lessees security of tenure "The agricultural leasehold

relation once established shall confer upon the agricultural lessee the right to continue
working on the landholding until such leasehold relation is extinguished. The agricultural
lessee shall be entitled to security of tenure on his landholding and cannot be ejected
therefrom unless authorized by the Court for causes herein provided"

The fact that the landowner entered into a civil lease contract over the same
land is not among the causes for extinguished of agricultural leasehold
relation.

Sec 10: Agricultural Leasehold Relation Not Extinguished by Expiration of Period, etc.The
agricultural leasehold relation under this code shall not be extinguished by 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. In case the agricultural lessor sells, alienates or
transfers the legal possession of the landhold-ing, the purchaser or transferee thereof
shall be subrogated to the rights and substituted to the obligations of the agricultural
lessor.

Hence, transactions involving the agricultural land over which an

agricultural leasehold subsists resulting in change of ownership will not
terminate the rights of the agricultural lessee who is given protection by
the law by making such rights enforceable against the transferee or the
landowners successor in interest.
The fact that private respondent knew of, and consented to, the said lease
contract by signing as witness to the agreement may not be construed as a
waiver of his rights as an agricultural lessee. On the contrary, it was his
right to know about the lease contract since, as a result of the agreement,
he had to deal with a new person instead of with the owners directly as he
used to.
The consent given by the original owners to constitute private respondent
as the agricultural lessee of the subject landholding binds private
respondents who, as successors-in-interest of the Spouses San Diego,
step into the latters shoes, acquiring not only their rights but also their
obligations
Fideli has unilaterally decided to pay only 25% of the net harvests to
petitioner but his agreement with the Spouses San Diego, the original
owners, was for a fifty-fifty (50-50) sharing of the net produce of the
land. The court held that the same sharing agreement should be
maintained between Endaya and Fideli. Hence, the Court ordered Fideli
to pay the back rentals from 190 -1992 + legal interest at legal rate.

(Doctrine: Once a leasehold relationship is established, the Agricultural

lessee is entitled to security of tenure)