PNR v.

Del Valle Facts: Philippine National Railways (PNR) owned three strips of land along the Manila- legazpi route, part of its railroad right of way. Some portions of the land were occupied by people, prompting disputes. PNR adopted temporary rules for the possession of the land through rentals. PNR awarded the use of the land after a bidding to Pantaleon Bingabing for a period of three years creating a civil law lease expressly stipulating Bingabing to "occupy and us the property. temporarily for agriculture." Bingabing failed to take possession of the said piece of land as Pampilo Doltz had occupied the land and claims that he is a tenant of the previous awardees and Bingabing too. In response to this, PNR and Bingabing filed suit against Doltz for recovery of the possession of the land, to remove the house of Doltz and pay for compensation to Bingabing. Doltz defenses state that he is inter alia tenant on the property for 20 years placed by deceased lessor Pablo Gomba, and successor Demetrio de Vera. He also claimed that he had given Bingabing 1/3 of the crop harvest profits and by effect become a tenant of Bingabing.Upon the court's request, Doltz and Bingabing agreed to temporarily liquidate the harvest on a sharing ratio of 70-30 in Doltz' favour. While the case was pending, Doltz registered with the Court of Agrarian Relations (CAR) a petition against Bingabing for security of tenure, the adoption of a sharing ratio of 70-30 of the crops, and reliquidation of past harvests. PNR intervened in the case. Petitioners herein there maintained the position that the premises in controversy are not an agricultural land within the contemplation of the Agricultural Tenancy Act (Republic Act 1199) or the Agricultural Land Reform Code (Republic Act 3844); that no tenancy relationship existed between the parties; that CAR, therefore, lacked jurisdiction over the case; and that there is a pending case between the same parties in another court involving the same subject matter and the same cause of action. CAR decided in favor of Doltz and that the sharing ratio be maintained. Issues: (1) Is the land in dispute agricultural land within the Agricultural Tenancy act and the Agricultural Land ref orm code? (2) Is Doltz considered a tenant? Held: (1) No. Section 3 of the Agricultural Tenancy Act, "agricultural tenancy is the physical possession by a person of land devoted to agriculture belonging to, or legally possessed by, another for the purpose of production through the labor of the former and of the members of his immediate farm household, in consideration of which the former agrees to share the harvest with the latter, or to

pay a price certain or ascertainable, either in produce or in money, or in both Section 166(1) of the Agricultural Land Reform Code, "agricultural land" means land devoted to any growth including but not limited to crop lands, salt beds, fishponds, idle land and abandoned land as defined in paragraphs 18 and 19 of this section The land here in controversy does not fit into the concept of agricultural land. PNR cannot devote it to agriculture because by its own charter, Republic Act 4156, PNR cannot engage in agriculture. Agricultural activities may hamper the operation, security and safety of the PNR. (2) The contract of lease executed by PNR in favour of Bingabing was merely temporary and may be revocable at any time the PNR needs the leased land for its own use. Also, the contract rules stipulate that any form of sublease of the land is prohibited and that previous awardees de Vera, Gomba or present leaseholder Bingabing cannot create one, since PNR did not consent to the creation of such.