G.R. No. L-18610 - Bermudez vs. Ferdo

Angel Bermudez and Isabelo Sampaga were tenants of Margarita Fernando.
The tenancy pertained to Fernando’s landholdings in barrio Sto. Niño Torcero, municipality of San Jose, Nueva Ecija.

For the agricultural year 1958–1959, the parties entered into tenancy contracts (Exhibits A and B).
A 50-50 sharing system was provided for the produce, with the transplanting expenses expressly charged to the respondent (Margarita Fernando).

The tenancy contracts were not renewed for the agricultural year 1960–1961.
In August 1960, Fernando tendered sums of P45.00 (for Bermudez) and P60.00 (for Sampaga) as payment for transplanting expenses.
Petitioners refused to accept the tendered amounts.

On September 15, 1960, Fernando consigned the required sums with the Court of Agrarian Relations (CAR), Cabanatuan City Branch (CAR Case No. 2188-NE’60).
Fernando prayed that the petitioners be compelled to accept these sums in discharge of her obligation to defray transplanting expenses for the year 1960–1961.

The petitioners asserted that in January 1960 they notified Fernando of their desire to change the tenancy system from share tenancy to leasehold tenancy pursuant to Section 14 of Republic Act No. 1189, as amended.
They further argued that they had already defrayed the transplanting expenses when Fernando tendered the amounts.

The lower court found insufficient evidence to support the petitioners’ claim of notifying the respondent about changing the tenancy system, noting the absence of such contention during their testimonies.
The court determined that Fernando’s tender was made before the commencement of the transplanting season, implying the petitioners had not incurred the expenses themselves.
Accordingly, the court declared that Fernando was deemed to have defrayed the transplanting expenses for 1960–1961.
It ordered the release of P45.00 to Bermudez and P60.00 to Sampaga, along with additional sums of P3.00 and P12.00, respectively.

The decision was appealed by the respondent.
The appellate court affirmed the lower court’s judgment, citing that the factual findings were fully supported by substantial evidence and referencing the precedent set in Atayde vs. de Guzman (103 Phil., 187).

Whether the petitioners validly notified the respondent of their desire to convert the tenancy from a share tenancy to a leasehold tenancy under Section 14 of Republic Act No. 1189, as amended.

Examination of the evidence provided by petitioners regarding the alleged notification.
Consideration of the absence of any mention of such conversion during the petitioners’ testimonies.

Whether the petitioners had already defrayed the transplanting expenses prior to the respondent’s tender in August 1960.

Analysis of the timing of Fernando’s tender relative to the commencement of the transplanting season.
Assessment of whether the tender offered an opportunity to settle the transplanting expenses by the petitioners.