Gabriel v PangilinanFactsGabriel entered into an oral contract of lease of a fishpond with Pangilinan. Desiring to develop and cultivate the fishpond by herself, she notified Pangilinan that she was terminating the contract. She demanded of the surrender of the fishpond but Pangilinan ignored.Pangilinan moved to dismiss the complaint on the ground that RTC has no jurisdiction as the proper court should be the Court of Court of Agrarian relations. Issue: W/O the relationship of the parties is an agricultural leasehold tenancy so that the proper court for the subject matter is the Court of Agrarian Relations?Held:No. A person who hires others to do the work ceases to be a tenant, which is a requisite in order that an agricultural tenancy relationship may exist. To be considered as a tenant, a person must himself and with the aid available from his immediate farm household cultivate the land. If he hires others and do not actually work for the land, he cannot be considered as tenant. In this case, defendant has ceased to work for the land as he became incapacitated.

De Jesus v. IACFactsDE Jesus and Rodirguez entered into a civil law contract of lease with Rodriguez. When the contract expired, de jesus refused to vacate the leased premises. RTc ruled in favor of de jesus stating that there was an agricultural tenancy relationship between them and thus CAR has jurisdiction. Ca reversed the rulng of the RTC stating that there was none as de jesus was not a small farmer and hired other person in cultivating the fishpond.Issue: W/O CA was correct?Held:Yes. Petitioner is not a small farmer but a business man. The Agricultural Land Reform Code was enacted to help the small farmers and to uplift their economic status. The mere fact that the land is an agricultural land does not ipso facto make the petitioner an agricultural lessee.