Title
Alicia Rodriguez and Fortunato Pizarro vs. Paulo Mariano and Court of Industrial Relations
Case
G.R. No. L-6523
Decision Date
Jan 31, 1955
Paulo Mariano claims tenancy rights after Alicia Rodriguez evicted him post-land purchase; Supreme Court remands for proper factual findings on tenancy vs. conditional possession.
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Case Digest (G.R. No. L-6523)

Facts:

1. Background of the Case:

  • Paulo Mariano filed a complaint before the Tenancy Law Enforcement Office, alleging that he was the tenant of Alicia Rodriguez for a parcel of land in Pilar, Bataan.
  • Mariano claimed that in May 1950, Rodriguez ordered him to vacate the land without just cause and replaced him with Fortunato Pizarro as the new tenant.
  • Rodriguez, in her defense, stated that she acquired the land from its former owner, Fausto Paguio, on March 3, 1950. She argued that Mariano’s possession of the land was conditional, based on a P600 loan extended by Mariano’s wife to Paguio, and that Mariano’s right to possess the land ceased after the loan was repaid.

2. Findings of the Tenancy Law Enforcement Office:

  • The Office found that Fausto Paguio was indebted to Ubaldo Crisostomo for P600 and borrowed the same amount from Mariano’s wife.
  • It was agreed that Mariano would cultivate the land and pay Paguio 50 cavanes of palay per agricultural year as rent.
  • Mariano cultivated the land for the 1949-1950 crop year and paid the agreed rental.
  • After receiving the rental, Paguio repaid the P600 loan to Mariano’s wife.
  • On March 3, 1950, Paguio sold the land to Rodriguez for P4,000, and Rodriguez installed a new tenant for the 1950-1951 crop year.

3. Decision of the Tenancy Law Enforcement Office:

  • The Office concluded that the relationship between Paguio and Mariano was that of landlord and tenant, and Mariano should be maintained in peaceful possession of the land.

4. Appeal to the Court of Industrial Relations:

  • Rodriguez appealed the decision to the Court of Industrial Relations, which affirmed the decision of the Tenancy Law Enforcement Office.
  • The Court of Industrial Relations did not fully discuss the evidence or address Rodriguez’s claim that Mariano’s possession was conditional on the loan.

Issue:

  1. Whether the relationship between Fausto Paguio and Paulo Mariano was that of landlord and tenant or merely a conditional arrangement based on a loan.
  2. Whether the Court of Industrial Relations properly evaluated the evidence and made sufficient factual findings to support its decision.
  3. Whether the case should be remanded to the Court of Industrial Relations for proper factual findings.

Ruling:

The Supreme Court remanded the case to the Court of Industrial Relations for proper findings of fact. The Court held that the decision of the Court of Industrial Relations was incomplete and lacked a proper evaluation of the evidence, particularly regarding the nature of the relationship between Paguio and Mariano. The Court emphasized that proper factual findings are necessary to determine whether Mariano is entitled to the benefits of the Rice Tenancy Law.

Ratio:

  1. Importance of Factual Findings: In petitions for review, only questions of law may be considered, and the findings of fact by the Court of Industrial Relations are generally conclusive. However, the Court cannot properly apply the law if the factual findings are incomplete or insufficient.
  2. Remand for Proper Evaluation: The case was remanded to ensure that the Court of Industrial Relations makes a proper evaluation of the evidence, particularly regarding the nature of the relationship between Paguio and Mariano. This is necessary to determine whether Mariano qualifies as a tenant under the Rice Tenancy Law.
  3. Conditional Possession vs. Tenancy: The Court highlighted the need to clarify whether Mariano’s possession of the land was conditional on the repayment of the P600 loan or if it constituted a tenancy relationship. This distinction is crucial in determining Mariano’s rights under the law.

Concurring Opinion

Justice Reyes concurred with the decision but clarified that the remand should explicitly set aside the previous decision of the Court of Industrial Relations. This would allow the court to render a new decision based on proper factual findings.


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