GRACIANO BERNAS, vs. THE HONORABLE COURT OF APPEALS and NATIVIDAD BITO-ON DEITA.
- G.R. Number: G.R. No. 85041
- Promulgated: 1993-08-05
- Ponente: Padilla, J.
Doctrine
An agricultural leasehold relation, once validly established, cannot be terminated except on grounds enumerated by law; those grounds are exclusive and cannot be supplemented by other alleged reasons.
A court may not decide questions or grounds not raised and litigated in the courts below; courts lack power to decide issues outside the issues properly in controversy.
Whether an agricultural leasehold exists is basically a question of law and cannot rest on one-sided findings by administrative investigators (e.g., MAR-investigator).
Facts
Benigno Bito-on was allowed to use plaintiff-owner Natividad Bito-on's land under a "dugo" arrangement so he could support his children's schooling; the exact nature of the transaction (usufruct or commodatum) was not established by evidence.
Graciano Bernas claimed rights as an agricultural leasehold lessee allegedly instituted by Benigno; Natividad disclaimed knowledge of any arrangement with Bernas.
The trial and appellate courts litigated whether Bernas is an agricultural leasehold lessee entitled to security of tenure and whether the parties were entitled to claimed damages.
The Court found insufficient evidence to show Benigno had authority to install a tenant or to create a tenancy coterminous with the schooling purpose, thus denying creation of a tenancy between Natividad and Graciano.
Issues
Whether the agricultural leasehold established by Benigno Bito-on in favor of Graciano Bernas is binding upon owner Natividad Bito-on, who disclaims knowledge of or participation in it.
Whether the parties are entitled to damages claimed in their respective pleadings.
Ruling
The petition is GRANTED: the Court reversed the Court of Appeals and reinstated the Regional Trial Court decision declaring Bernas an agricultural leasehold lessee with security of tenure over specified lots, and dismissed plaintiffs' complaint; costs against private respondent.
Alternatively, the Court held there was no sufficient evidence that Benigno or Graciano were lessee-tenants entitled to security of tenure, finding Benigno was merely an encargado enjoying produce for his children and that no tenancy was created between Natividad and Graciano.
Keywords
G.R. No. 85041, agricultural leasehold lessee, security of tenure, Recovery of Possession, Ownership and Injunction with Damages, Republic Act No. 1199, Republic Act No. 3844, Agricultural Land Reform Code, usufruct, commodatum, bailor-bailee, privity of contract, Generalibus specialia derogant, Agricultural Tenancy Act of the Philippines, agricultural tenancy relations, share tenancy, leasehold tenancy, Section 4 of this Code, Section 5 of this Code, Section 6 of this Code, Section 7 of this Code