TEODORO vs MACARAEG

No. L-20700; 27 February 1969

Jose Rizal College v National Labor Relations Commission and National Alliance of Teachers/Office Workers (NATOW)
Petitioner Respondents
Macaraeg filed a petition with CAR, praying that (1) an interlocutory order be issued to restrain Teodoro
and Niegos from ejecting him from his landholding pending resolution of his petition and (2) after due trial,
he be maintained as lawful tenant in disputed landholding.
- that he is a leasehold tenant of Teodoro cultivating a farmholding situated in Nueva Ecija, of a 4
hectare area devoted to rice culture
- he worked as tenant for last 7 years.
- On 2 March he received a letter from Teodoro and his wife advising him that landholding will be given
to another tenant
FACTS:

- Teodoro placed a new tenant, Niegos, who forbade him from working on the riceland
Teodoro denied that Macaraeg was his tenant, claiming that ever since he became the owner of the 39
hectare Riceland, he had always leased all of it under civil lease. After expiration of lease contract with
Macaraeg, his wife twice notified Macaraeg to renew contract for incoming agricultural year but he said he
was no longer interested.
Niegos answered disclaiming any knowledge that Macaraeg is the tenant of Teodoro and that he entered
the landholding in good faith clothed with property authority from other respondent.
Macaraeg filed a supplemental petition claiming damages as a result of dispossession.
CAR rendered in favor of Macaraeg.
Upon reconsideration, Court granted Macaraegs prayer for damages.
W/N Macaraeg became a tenant of Teodoro by virtue of the Contract of Lease
ISSUE:
W/N Macaraeg is guilty of abandonment which terminated tenancy relation
HELD: Yes and No.
Teodoro SC
The language and Untenable. It bears emphasis that the title, label or rubric given to a contract
tenor of contract cannot be used to camouflage the real import of an agreement as evidenced by
clearly manifest the its main provisions. It is basic that a contract is what the law defines it to be, not
intention of parties to what it is called by the contracting parties.
enter into an ordinary - we have no doubt that the lease contract entered into between petitioner
civil lease contract, (Macaraeg) and Fidel Teodoro is a pure and simple leasehold tenancy contract
not a leasehold as the term is understood under our tenancy laws. This observation of the
tenancy agreement as agrarian court finds anchor in the pertinent provisions of the Agricultural
alleged by Macaraeg. Tenancy Act. Thus, section 4 of Rep. Act 1199, as amended by Rep. Act 2263,
Contract of lease The mere fact that parties fixed a limited duration of their lease contract to only
cannot possibly be 1 agri year does not remove relationship which they created from purview of
construed as leasehold tenancy.
establishing leasehold It is fundamental that tenant-lessees security of tenure subsists
RULING:

when it shall only be notwithstanding the termination of contract which initially established tenancy
for agricultural year
1960-61
Sec 42 Agricultural Tenancy Act defines
- landlord-lessor as any person natural or juridical either as owner, lessee, usufructuary or legal
possessor for purposes of agricultural production and for a price certain or ascertainable either in
amount or produce.
- Tenant-lessee is any person who, with consent of landlordlessor, tills cultivated, or operates land
susceptible of cultivation by one individual personally or with aid of labor available from among his
own immediate farm household.
 The following are the principal elements of a leasehold tenancy contract or relation:
1. object of contract or relationship is an agricultural land leased for purpose of agri production
2. size of landholding must be such that it is susceptible of personal cultivation by single person with
assistance from members of immediate farm household
3. tenant-lessee must actually and personally till cultivate or operate said land with aid from immediate
farm household and
4. landlord who is either lawful owner or legal possessor of land leases the same to tenant lessee for a
price certain or ascertainable either in money or produce.
Reverting to the controverted Contract of Lease, we are of the consensus that it indubitably contains the
foregoing essential elements of a leasehold tenancy agreement.
1. Landholding is an agricultural land devoted to agricultural production Land to be used for rice
production
2. Land is susceptible of cultivation by a single person. Only 4/1 hectares
3. Rental to be paid must be produced by lessee meaning Macaraeg must personally work the land
4. Rental of 9 cavans of palay per hectare for 1 agri year
Evidently there was a valid leasehold tenancy agreement.

On Abandonment
Anent the charge of abandonment, it is also pertinent to note that four days after Macaraeg received a letter
from Teodoro and his wife advising him that the landholding in question will be given to another tenant, he
lost no time in inquiring from the Tenancy Mediation Commission at Cabanatuan City about his rights as a
leasehold tenant. It would appear therefore that Macaraegs immediate reaction to his landlords design to
dispossess him negates the act of abandonment imputed to him.