Facts:

The case involves Francisco Baligwat as the petitioner and Albino Estavas as the respondent, with the decision rendered by the Supreme Court of the Philippines on April 8, 1986. Baligwat was a tenant over 1.5 hectares of coconut land owned by Estavas located in Pualas, Tubod, Lanao del Norte. The conflict arose when Estavas expressed a desire to eject Baligwat from the land, asserting that he intended to cultivate it personally. On February 7, 1971, Estavas sent a letter to Baligwat, notifying him of this intention, which was received through the local Barrio Captain. One year after this notice, on April 4, 1972, Estavas filed a complaint for ejectment against Baligwat due to his failure to vacate the premises. Estavas claimed against Baligwat based on his experience as a farmer and the fact that other portions of his land were already being cultivated by his children. Prior litigation in the lower courts included a decision by the Court of Agrarian Reforms which upheld Estavas’

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Facts:

Background of the Parties

• Francisco Baligwat is the tenant of Albino Estavas over a tenanted portion of a larger coconut landholding.
• The landholding consists of 26 hectares, of which Baligwat occupies and cultivates one and one-half hectares exclusively devoted to coconut trees.

Basis for the Dispute

• Albino Estavas, the landowner, sought to eject Baligwat on the ground that he wished to personally cultivate the tenanted land.
• Personal cultivation was a recognized ground for dispossessing a tenant under Section 50 of Republic Act 1199 (Agricultural Tenancy Act).

Notification and Procedural Steps

• Estavas notified Baligwat of his intention to personally cultivate the area by sending a letter dated February 7, 1971 (identified as Exhibit “B”), which was received via the local Barrio Captain.
• In compliance with legal requirements, Estavas filed a notice with the Court on February 15, 1971 (Exhibit “C” and its copy Exhibit “C-1”).
• After one year, Estavas sent a reminder letter (Exhibit “D”) that Baligwat should vacate the premises after February 1972.
• When Baligwat failed to vacate, Estavas filed his petition to eject on April 4, 1972 (Exhibit “E”).

Additional Context of the Land

• Estavas’s intention to personally cultivate the one and one-half hectares was grounded on his prior farming experience and the fact that the rest of his land was being cultivated by his children.
• Estavas’s family details are provided: he and his wife acquired parts of the land, and his children, some with their own houses, cultivate the remaining portions.

Legal Provisions and Acts at Issue

• The dispute centers on whether personal cultivation as a ground for dispossession has been repealed by Section 7 of Republic Act 6389.
• The contentious legal interpretation involves the applicability of the Agricultural Tenancy Act for coconut lands, referencing Section 35 of Republic Act 3844 and Section 1 of Presidential Decree No. 1425.

Relevant Case History

• The Court of Agrarian Reforms denied Estavas’s motion to dismiss Baligwat’s complaint.
• The decision of the Court of Appeals (later affirmed by this Court) upheld that personal cultivation remains a valid ground for dispossession where coconut lands are concerned.
• Petitioner Baligwat cited the earlier Arambulo vs. Conicon case to argue for the repeal of the personal cultivation ground, but noted that this case pertained to rice lands and not coconut lands.
• The en banc decision in Nilo vs. Court of Appeals ultimately reversed the precedent set in Arambulo regarding the retroactive effect of Republic Act 6389.

Issue:

Whether personal cultivation as a ground for dispossessing a tenant under Section 50 of Republic Act 1199 remains valid for coconut lands despite the enactment of Republic Act 6389.

• The dispute specifically addresses the applicability of the repeal provision in RA 6389 to coconut lands.
• It questions if the legislative intent to abolish personal cultivation as a basis for dispossession extended to lands principally planted to permanent trees.

Whether the decision in Arambulo vs. Conicon, which supported the contention that personal cultivation had been repealed, should continue to be considered controlling law.

• The petitioner relies on the earlier decision (and its affirmation) to support his argument.
• The issue is compounded by the en banc decision in Nilo vs. Court of Appeals which effectively reversed the earlier ruling.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)