Title
Barias vs. Alcantara
Case
G.R. No. L-56564
Decision Date
Oct 18, 1982
Filomeno Barias claimed tenancy on a seven-hectare land, alleging constructive ejection after his father’s death. The Supreme Court ruled against him, citing insufficient evidence, credibility issues, and procedural errors in suing his stepmother instead of the estate administrator.
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Case Digest (G.R. No. L-56564)

Facts:

Family Background and Land Ownership

  • Filomeno Barias is the son of Domingo Barias and Josefina Alvarez. Josefina died in 1953, and Domingo remarried Eduarda Alcantara in 1958. Domingo died in 1977.
  • Domingo had eight children from his first marriage (including Filomeno) and five children from his second marriage with Eduarda.
  • Domingo executed a will in 1973, devising a seven-hectare land to his second wife and their children. The will was probated in 1975, and the estate is under administration in Special Proceeding No. C-28.

Filomeno’s Claim of Tenancy

  • Filomeno claimed he was instituted as a tenant on the seven-hectare land in 1945 when he was 16 years old. He alleged he planted coconuts, lanzones, bananas, and coffee on the land and received a one-fifth share of the harvests.
  • After Domingo’s death in 1977, Filomeno continued working on the land but claimed his stepmother, Eduarda, received the proceeds of the harvests, effectively "constructively ejecting" him.

Evidence Presented by Filomeno

  • Filomeno testified that he planted 150 coconut trees, 1,200 lanzones trees, and other crops on the land. He claimed his father promised him a one-fifth share of the harvests.
  • Witnesses, including barangay captain Guillermo de Ocampo and neighbors, testified that they saw Filomeno working on the land and selling its produce. However, none could confirm the exact terms of his tenancy or his share of the harvests.

Eduarda’s Defense

  • Eduarda denied Filomeno was ever a tenant on the land. She stated that the land was cleared and planted by hired workers, not Filomeno.
  • She presented evidence that three of the lots in question were acquired after 1945, making it impossible for Filomeno to have been a tenant on those parcels since that year.
  • Eduarda also testified that Filomeno entered the land after Domingo’s death and destroyed some plants, as shown in photographs and corroborated by witness Teresita Agapay.

Trial Court’s Findings

  • The trial court found Filomeno’s evidence unreliable. It noted inconsistencies, such as the lack of a sketch of the land and the presence of other tenants on portions of the land.
  • The court also found Eduarda’s testimony more credible, especially regarding Filomeno’s entry into the land after Domingo’s death and his acts of vandalism.

Issue:

  1. Whether Filomeno Barias was a tenant on the seven-hectare land and whether he was "constructively ejected" after his father’s death.
  2. Whether Filomeno is entitled to be maintained in peaceful possession of the land and to receive a one-fifth share of the harvests.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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