PNR vs Del Valle Facts:

PNR, a government-owned corporation, is the registered owner of three strips of land the same being part of its railroad right of way running from Manila to Legazpi. The portions of these lands not actually occupied by the railroad track had been a source of trouble. People occupied them and they reap profits there from. Disputes among those desiring to occupy them cropped up. Because of this, PNR adopted temporary rules and regulations to settle the said disputes. Sometime in 1963, PNR awarded the portions of the three strips of land to petitioner Pantaleon Bingabing for a period of 3 years. A civil law lease contract in printed form was entered into between PNR and Bingabing. The contract expressly stipulates that Bingabing was "to occupy and use the property temporarily for agriculture. Bingabing failed to take possession because respondent Pampilo Doltz was occupying the land and had a house thereon. Doltz claims to be a tenant of previous awardees, and later, of Bingabing himself. Issue: Whether or not strips of land owned by Philippine National Railways (PNR) are agricultural lands within the purview of the Agricultural Tenancy Act and the Agricultural Land Reform Code Held: No. According to Section 3 of the Agricultural Tenancy Act, "[a]gricultural 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." On the otherhand, the term "agricultural land" as understood by the Agricultural Land Reform Code is not as broad in meaning as it is known in the constitutional sense. As interpreted in Krivenko vs. Register of Deeds, the phrase "agricultural land," constitutionally speaking, includes all lands that are neither mineral nor timber lands and embraces within its wide sweep not only lands strictly agricultural or devoted to cultivation for agricultural purposes but also commercial, industrial, residential lands and lands for other purposes. On the other hand, by Section 166(1) of the Agricultural Land Reform Code," '[a]gricultural 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, respectively." It is obvious then that under the law, 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.

Philbancor vs CA Facts: Private respondents Alfredo Pare, Pablo Galang and Amado Vie are tenants of petitioner Hizon over his landholdings in Balite, San Fernando Pampanga. Hizon, without the private respondents knowledge, mortgaged said properties with petitioner corporation Philbancor Finance Inc. The properties were later foreclosed by the corporation and a certificate of sale was issued and registered with the Registry of Deeds on July 31, 1985. On July 14, 1992, private respondents sought to redeem the properties through the filing a complaint with the Provincial Agrarian Reform Adjudication Board (PARAB) of San Fernando, Pampanga, which rendered a decision favorable to private respondents and which was affirmed by the Department of Agrarian Reform Adjudication Board (DARAB). Petitioners filed a petition for review with the Court of Appeals which, however, dismissed their petition. Their motion for reconsideration having been denied, they filed this present petition with this Court. Issue: Whether or redemption Held: Yes. Under Section 12 of Republic Act No. 3844 the right of redemption of an agricultural lessee must be exercised within 2 years from the registration of the sale. In the case at bar, the certificate of sale was registered with the Register of Deeds of Pampanga on July 31, 1985. The two-year redemption period expired on July 31, 1987. The complaint for redemption was filed by respondents only on July 14, 1992, five years after expiration of the redemption period. Nevertheless, they may continue in possession and enjoyment of the land as tenants for leasehold is not extinguished by the alienation or transfer of the landholding.

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