Jaime Sanchez v.

Zenaida Marin
GR No. 171346 19 October 2007

FACTS:

David Felix owned a fishpond. Jaime Sanchez was instituted as a tenant on the said fishpond, with a 50/50
sharing agreement. After a few years, Felix sold and transferred ownership of the subject fishpond to the
Marins. As new owners of the fishpond, they entered into a civil law agreement with their mother, Zemaida,
which was renewable yearly.

Zenaida then made an arrangement with Jaime Sanchez wherein Sanchez would receive a regular salary
and a 20% share in the net profit of the fishpond. When her lease agreement with her children expired,
Zenaida ordered Sanchez to vacate the premises. Sanchez refused, asserting that he was a tenant of the
fishpond and not a mere contractual worker; hence, he had the right to its peaceful possession and security
of tenure. He then asked the court to declare him as a tenant of the subject fishpond, which subsequently
did.

As Sanchez was already declared as an agricultural tenant of the fishpond, he filed a petition to the
Provincial Agrarian Reform Adjudicator (PARAD) for the fixing of leasehold rentals for his use of the
fishpond. However, Zenaida countered this application by filing a case with the PARAD to eject Sanchez
for failure to pay the rent and for failure to render an accounting. The PARAD consolidated the 2 cases and
ruled in favor of Sanchez.

Zenaida appealed to the DARAB, which affirmed the PARAD decision. The CA reversed the ruling, stating
that the DARAB lacked jurisdiction over the case. It stated that Sec. 2 of RA 7881, which amended Sec. 10
of RA 6657, excluded private lands actually, directly, and exclusively used for prawn farms and fishponds
from the coverage of the CARL, so that the operation of a fishpond is no longer considered an agricultural
activity. Since the cases are not agrarian disputes, then the DARAB could not have validly acquired
jurisdiction over the case.

Issues:

1. Whether or Not a fishpond is an agricultural land. – NO.

2. Whether or Not a tenurial arrangement exists between Sanchez and Zenaida Marin. – YES.
3. Whether or Not the DARAB has jurisdiction over the case. – YES.

RULING:

1. By virtue of Sec. 2, RA 7881, the operation of fishponds is no longer considered an agricultural activity,
and a parcel of land devoted to fishpond operation is no longer an agricultural land.

2. Although the fishpond is not covered by the CARL, it bears emphasis that Sanchez’ status as a tenant
in the subject fishpond and his right to security of tenure were already previously settled. Having been
declared as a tenant with the right to security of tenure as provided by the law enforced at the time of
the filing of the complaint, Sanchez has acquired a vested right over the subject fishpond. Therefore,
even if fishponds were later excluded/exempted from CARL coverage, and despite the fact that no
CLOA has been issued to Sanchez, the same cannot defeat the aforesaid vested right already granted
and acquired by Sanchez long before the passage of RA 7881.

3. The present case was instituted as early as 1991 when the law applicable was still RA 6657, and
fishponds and prawn farms were not yet exempted/excluded from the CARL coverage. At that time,

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 there was an agrarian dispute between the parties. Prior to the enactment of RA 7881 in 1995, the case
was already pending appeal before the DARAB. Hence, the aforesaid amendments cannot be made to
apply to divest the DARAB of its jurisdiction of the case. Once jurisdiction is acquired by the court, it
remains with it until the full termination of the case.

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