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    PNR Vs Del Valle

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    Mis Dee
    This case involves a dispute over possession of three strips of land totaling 30 meters wide adjoining a railroad right of way between PNR and Del Valle. PNR had awarded the land to Bingabing for three years, but Del Valle was occupying the land and claimed to be a tenant of previous occupants. While a case for recovery of possession was pending, Del Valle filed for security of tenure with the Court of Agrarian Relations. The Court ruled the land was not agricultural land governed by laws on agricultural tenancy. The land was part of PNR's railroad right of way, whose use for agriculture would be inconsistent with railroad operations. Additionally, PNR prohibited subleasing of the land, so no tenant

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    PNR Vs Del Valle

    Uploaded by

    Mis Dee
    144 views1 page
    This case involves a dispute over possession of three strips of land totaling 30 meters wide adjoining a railroad right of way between PNR and Del Valle. PNR had awarded the land to Bingabing for three years, but Del Valle was occupying the land and claimed to be a tenant of previous occupants. While a case for recovery of possession was pending, Del Valle filed for security of tenure with the Court of Agrarian Relations. The Court ruled the land was not agricultural land governed by laws on agricultural tenancy. The land was part of PNR's railroad right of way, whose use for agriculture would be inconsistent with railroad operations. Additionally, PNR prohibited subleasing of the land, so no tenant

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    PNR vs Del Valle

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    PNR vs Del Valle

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    This case involves a dispute over possession of three strips of land totaling 30 meters wide adjoining a railroad right of way between PNR and Del Valle. PNR had awarded the land to Bingabing for three years, but Del Valle was occupying the land and claimed to be a tenant of previous occupants. While a case for recovery of possession was pending, Del Valle filed for security of tenure with the Court of Agrarian Relations. The Court ruled the land was not agricultural land governed by laws on agricultural tenancy. The land was part of PNR's railroad right of way, whose use for agriculture would be inconsistent with railroad operations. Additionally, PNR prohibited subleasing of the land, so no tenant

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    144 views1 page

    PNR Vs Del Valle

    Uploaded by

    Mis Dee
    This case involves a dispute over possession of three strips of land totaling 30 meters wide adjoining a railroad right of way between PNR and Del Valle. PNR had awarded the land to Bingabing for three years, but Del Valle was occupying the land and claimed to be a tenant of previous occupants. While a case for recovery of possession was pending, Del Valle filed for security of tenure with the Court of Agrarian Relations. The Court ruled the land was not agricultural land governed by laws on agricultural tenancy. The land was part of PNR's railroad right of way, whose use for agriculture would be inconsistent with railroad operations. Additionally, PNR prohibited subleasing of the land, so no tenant

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 1

    PNR vs Del Valle

    Facts:

    PNR, a government-owned corporation, is the registered


    owner of three (3) strips of land with a uniform width of 30.
    meters adjoining one another longitudinally, the same being
    part of its railroad right of way running from Manila to
    Legazpi.

    Sometime in 1963, PNR awarded the portions of the three


    strips of land aforementioned which are on both sides of the
    track, not actually occupied by the railroad track, after a
    competitive public bidding, to petitioner Pantaleon Bingabing
    for a period of three (3) years and under conditions
    hereinbefore set forth. Bingabing, however, failed to take
    possession because respondent Pampilo Doltz was occupying
    the land, had a house thereon. Doltz claims to be a tenant of
    previous awardees, and later, of Bingabing himself.

    Sometime in March 1965, PNR and Bingabing filed suit


    against Doltz for recovery of possession of the premises in the
    Court of First Instance of Albay.

    Doltz' answer in that case averred inter alia that the had been
    a tenant on the property for over twenty years; that he had
    been placed thereon by the deceased Pablo Gomba who
    leased the property from the then Manila Railroad Company
    (now PNR); that he became the tenant of Demetrio de Vera,
    Gomba's successor; that he is the tenant of Bingabing, having
    given the latter's share of 1/3 during the last two harvests;
    and that the case is properly cognizable by the Court of
    Agrarian Relations.

    While the aforesaid Civil Case 3021 was pending in the Albay
    court of first instance, 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.

    Petitioners opposed and maintained that CAR has no


    jurisdiction over the case. CAR, nevertheless, resolved in
    favor of Doltz. Hence, this petition.
    Issue: W/N the land here involved an agricultural land within the
    meaning of the Agricultural Tenancy Act and the Agricultural Land
    Reform Code?
    Ruling: 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."

    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

    Indeed, the land which adjoins the railroad track on both


    sides is part of PNR's right of way. That right of way is not
    limited to the particular space occupied by the roadbed or its
    main track. It also includes the portions occupied by the
    telephone and telegraph posts. It extends to a width of 30
    meters which reasonably gives the train locomotive engineer
    a clear commanding view of the track and its switches ahead
    of him.

    Besides, the use of the strips of land on both sides of the track
    in railroad operation is inconsistent with agricultural
    activities.

    Even on the assumption that the land is agricultural, there is


    the circumstance that PNR prohibits the sublease of the
    premises. PNR's lessees cannot give what they are not
    allowed to give.

    This ushers us to a principle shaped out by jurisprudence that


    the security of tenure guaranteed by our tenancy law may be
    invoked only by tenants de jure, not by those who are not true
    and lawful tenants.

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