Facts:

The case involves Timoteo Andres and 45 other petitioners, who were tenants of the De Santos Agricultural Development Co., Inc., represented by Alberto de Santos. The petitioners filed a complaint on February 10, 1962, seeking a change in their crop-sharing arrangement from 55%-45% to 70%-30% in their favor for the agricultural year 1961-62. This complaint was dismissed by the Court of Agrarian Relations in Guimba, Nueva Ecija, in CAR Case No. 728, on November 9, 1962, due to lack of timely notice to the landowners as required by Section 14 of Republic Act No. 1199. The petitioners claimed that they sent a letter through their counsel, Atty. Eliseo Tenza, to Alberto de Santos on March 1, 1961, and a second notice on March 15, 1961, but the court found insufficient evidence to prove that these notices were received at least a month before the agricultural year commenced. The trial court ruled in favor of the respondents, denying the petitioners' request for a change in the...

Facts:

Background and Parties

• Forty-six tenant-petitioners, operating under a crop-sharing arrangement with respondent landowner Alberto de Santos and his corporation, De Santos Agricultural Development Co., Inc., sought to change their sharing ratio from 55%-45% to 70%-30% in their favor.
• The petitioners filed their Petition for Certiorari on January 17, 1963, after a previous complaint for a change in sharing for the agricultural year 1961-62 was dismissed by the Court of Agrarian Relations, Guimba, Nueva Ecija.

Notice and Evidence of Timely Communication

• Petitioners, through their counsel Atty. Eliseo Tenza, sent two separate notices to respondent landowner Alberto de Santos:
• The first letter, sent in the first week of March 1961, expressed the desire to change the crop-sharing arrangement.
• The second letter, mailed on or about March 15, 1961, duplicated the first notice and was sent in one envelope containing both notices (marked as Exhibits L and M).
• Copies of these notices were also sent to other key parties:
• The Court of Agrarian Relations at Guimba.
• The municipal treasurer of Guimba.
• The Provincial Fiscal.
• Attorneys representing the respondent corporation (Attys. Jose Dacquel and Florencio Florendo).
• Evidence presented included registry receipts:
• Registered letter No. 7435 (sent on March 2, 1961) received by an authorized agent (Felipe Miguel).
• Registered letter No. 9171 (sent on March 15, 1961) which was not claimed by respondent Alberto de Santos despite repeated notices.

Dismissal by the Trial Court

• The trial court dismissed the petition on November 9, 1962, holding that there was insufficient evidence to prove that the notice had been sent and received at least one month prior to the commencement of the agricultural year 1961-62, as required by Section 14 of R.A. 1199 (as amended).
• The dismissal was based on several points:
• Denials by respondent Alberto de Santos regarding receipt of the notices.
• The absence of the original documents—petitioners only submitted duplicate copies marked as Exhibits L and M.
• Discrepancies regarding the contents and transmission of the registered letters.
• The trial court’s reliance on technicalities and the non-production of the original registered letter No. 9171 and the registry return card for letter No. 7435.

Appeal and Re-examination of Evidence

• Petitioners raised two main errors on appeal:
• That the Court of Agrarian Relations erred in not ordering the new crop-sharing ratio (70%-30%) in their favor.
• That the court improperly ruled against the admissibility of key exhibits (Exhibits L and M) and thus dismissed the petition.
• The appellate review carefully re-examined the evidence, giving due weight to:
• Atty. Tenza’s testimony regarding the dispatch and contents of the notices.
• The corroborative testimony of the postmaster of Guimba, who confirmed the receipt of the registered letters according to official records.
• The appellate court noted that despite technical deficiencies (such as the non-production of original documents), the credible postmaster records and corroborative evidence sufficed to establish that timely notice had been given.

Issue:

• Whether the petitioners provided timely notice to the respondent-landowners as mandated under Section 14 of the Agricultural Tenancy Act (R.A. 1199 as amended) in order to effect a change in the crop-sharing arrangement for the agricultural year 1961-62.

• Whether the trial court erred in dismissing the petition on the ground that the notice was not received at least one month prior to the commencement of the agricultural year, despite the presented documentary and testimonial evidence.

• Whether the admissibility issues concerning the duplicate copies (Exhibits L and M) and the absence of original registry documents should preclude the determination of the petitioners’ compliance with the statutory notice requirements.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)