Title
Andres vs. Santos
Case
G.R. No. L-20672
Decision Date
Feb 28, 1974
Tenants sought a crop-sharing change from 55%-45% to 70%-30%; Supreme Court ruled in their favor, citing timely notice and social justice principles.
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Case Digest (G.R. No. L-20672)

Facts:

  1. Parties Involved:

    • Petitioners: Forty-six tenants of the De Santos Agricultural Development Co., Inc.
    • Respondents: Alberto de Santos (manager), De Santos Agricultural Development Co., Inc., and Hon. Pastor P. Reyes (Judge, Court of Agrarian Relations, Guimba, Nueva Ecija).
  2. Background:

    • Petitioners were tenants of the respondent corporation and sought to change their crop-sharing arrangement from 55%-45% (in favor of the landowner) to 70%-30% (in favor of the tenants) for the agricultural year 1961-62.
  3. Notice of Change:

    • On March 1, 1961, the first group of petitioners sent a letter through their counsel, Atty. Eliseo Tenza, to Alberto de Santos, requesting the change. Copies were sent to the Court of Agrarian Relations, the Provincial Fiscal, the municipal treasurer of Guimba, and the lawyers of the respondent corporation.
    • On March 15, 1961, the second group of petitioners sent a similar notice.
  4. Refusal and Complaint:

    • Despite the notices, the respondent-landowners refused to implement the new sharing arrangement.
    • Petitioners filed a complaint on February 10, 1962, in CAR Case No. 728, seeking enforcement of the 70%-30% sharing arrangement.
  5. Trial Court Decision:

    • The Court of Agrarian Relations dismissed the complaint on November 9, 1962, ruling that petitioners failed to prove timely notice of the change as required under Section 14 of R.A. 1199 (Agricultural Tenancy Act).
  6. Appeal:

    • Petitioners appealed to the Supreme Court, arguing that the trial court erred in dismissing their complaint and in ruling against the admissibility of Exhibits "L" and "M" (copies of the notices).

Issue:

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Ruling:

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Ratio:

  1. Timely Notice:

    • The Court found that petitioners complied with the requirement of Section 14 of R.A. 1199, which mandates that notice of a change in the sharing arrangement must be given at least one month before the start of the agricultural year.
    • The testimonies of Atty. Eliseo Tenza and the postmaster of Guimba, supported by documentary evidence, proved that the notices were sent and received by the respondent-landowners.
  2. Presumption of Receipt:

    • Under Section 8, Rule 13 of the Rules of Court, service by registered mail is deemed complete upon actual receipt or after five days from the first notice if the addressee fails to claim the mail.
    • The Court applied this presumption, noting that the registered letters were either received by an authorized agent of the respondent-landowner or remained unclaimed despite multiple notices.
  3. Social Justice Principle:

    • The Court emphasized the principle of social justice underlying the Agricultural Tenancy Act, which aims to protect the rights of tenants and improve their economic condition.
    • Technicalities should not hinder the enjoyment of tenants' rights, especially when the evidence supports their claims.
  4. Admissibility of Evidence:

    • The Court ruled that the duplicate copies of the notices (Exhibits "L" and "M") were admissible, as the postmaster's testimony corroborated their existence and timely delivery.
  5. Effectivity of Change:

    • The Court held that even if the notice for 1961-62 was disputed, the filing of the complaint in February 1962 constituted sufficient notice for the agricultural year 1962-63.


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