LERMA L.

CASTILLO
BLOCK B

ENDAYA VS. CA
GR: 88113

FACTS:

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. 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: Whether or not Fideli is an agricultural tenant of petitioner

RULING:

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 landowner’s 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 latter’s 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.