FACTS:

Petitioner Espiridion Tanpingco is the tenant-lessee of a parcel of agricultural riceland owned by respondent Benedicto Horca, Sr. in Brgy. Buenavista, Jaro, Leyte. On April 9, 1985, the respondent informed the petitioner to stop working on the land, as it had already been donated on February 3, 1985 to the Ministry of Education, Culture and Sports, Region VIII, to be used as the site for the Buenavista Barangay High School. The respondent ordered the petitioner to vacate the landholding, prompting the petitioner to file a complaint for payment of disturbance compensation with damages.

The case was called for pre-trial on July 5, 1985, and the respondent was given until July 9, 1985, to file an answer. However, the respondent filed a Motion to Dismiss, arguing that he was not the real party-in-interest since he had already donated the land, and therefore, no disturbance compensation is due. The trial court granted the motion to dismiss, and the petitioner's motion for reconsideration was denied.

The Intermediate Appellate Court affirmed the trial court's decision, prompting the petitioner to file a petition for review on certiorari. In his petition, the petitioner raised three assignment of errors: (1) whether it was proper for the trial court to grant the motion to dismiss, (2) whether the conversion of the tenanted riceland into a school site was valid, and (3) whether a tenant is entitled to payment of disturbance compensation when the tenanted land is donated and converted into a school site.

ISSUES:

1. May a tenanted parcel of land be donated by the landowner without securing the consent of the tenant-lessee?

2. Who bears the responsibility of paying disturbance compensation?

RULING:

1. The trial court was correct in granting the Motion to Dismiss filed by the defendant. The respondent court noted that the filing of the motion to dismiss and its granting expedited the proceedings and conforms with the spirit and intention of Presidential Decree No. 946, which requires courts trying agrarian cases to employ every reasonable means to ascertain the facts of every case in accordance with justice and equity without regard to technicalities of law and procedure.

2. The respondent court was correct in ruling that a tenant is not entitled to payment of disturbance compensation in case the tenanted landholding is donated and converted into a school site. The court held that disturbance compensation holds true only in cases wherein the lessor-owner derives financial benefits from the conversion of the agricultural land into non-agricultural purposes.

PRINCIPLES:

• When the law speaks in clear and categorical language, there is no room for interpretation. However, technicalities may be disregarded in order to resolve the case on its merits.

• Courts trying agrarian cases are required to employ every reasonable means to ascertain the facts of every case in accordance with justice and equity without regard to technicalities of law and procedure.