Case Digest (G.R. No. L-18610)
Facts:
The case involves Angel Bermudez and Isabelo Sampaga as petitioners against Margarita Fernando, the respondent. The events took place in the agricultural year 1958-1959, concerning landholdings located in barrio Sto. Nino Torcero, municipality of San Jose, Nueva Ecija. Bermudez and Sampaga were tenants of Fernando and had entered into tenancy contracts (Exhibits A and B) that stipulated a sharing system of 50-50, with the transplanting expenses to be borne by the respondent. However, these contracts were not renewed for the agricultural year 1960-1961. In August 1960, the petitioners refused to accept the amounts of P45.00 and P60.00, which were offered by the respondent to cover their planting expenses. Consequently, on September 15, 1960, Fernando consigned these amounts with the Court of Agrarian Relations in Cabanatuan City (CAR Case No. 2188-NE'60), seeking to compel the petitioners to accept the payments as fulfillment of her obligation for the transplanting expense...
Case Digest (G.R. No. L-18610)
Facts:
Parties Involved:
- Petitioners: Angel Bermudez and Isabelo Sampaga (tenants).
- Respondent: Margarita Fernando (landowner).
Location and Tenancy Contracts:
- The landholdings are situated in Barrio Sto. Nino Torcero, San Jose, Nueva Ecija.
- For the agricultural year 1958-1959, the parties entered into tenancy contracts (Exhibits A and B), which stipulated a 50-50 sharing system, with transplanting expenses to be shouldered by the respondent.
Non-Renewal of Contracts:
- The tenancy contracts were not renewed for the agricultural year 1960-1961.
Dispute Over Transplanting Expenses:
- In August 1960, respondent tendered P45.00 to Bermudez and P60.00 to Sampaga for transplanting expenses, but petitioners refused to accept the amounts.
- On September 15, 1960, respondent consigned the amounts with the Court of Agrarian Relations (CAR Case No. 2188-NE'60) and sought to compel petitioners to accept the payments.
Petitioners' Claims:
- Petitioners alleged that in January 1960, they notified respondent of their desire to change their tenancy system from sharehold to leasehold under Section 14 of Republic Act No. 1189, as amended.
- They also claimed to have already defrayed the transplanting expenses when respondent tendered the amounts.
Lower Court's Decision:
- The Court of Agrarian Relations ruled:
(1) Respondent was deemed to have defrayed the transplanting expenses for 1960-1961.
(2) The Clerk of Court was ordered to release the consigned amounts to petitioners.
(3) Respondent was ordered to pay additional sums of P3.00 to Bermudez and P12.00 to Sampaga.
- The Court of Agrarian Relations ruled:
Appeal:
- Petitioners appealed the decision, but the lower court found no sufficient evidence to support their claims regarding the change to leasehold tenancy or their prior payment of transplanting expenses.
Issue:
- Whether petitioners validly notified respondent of their desire to change the tenancy system from sharehold to leasehold.
- Whether petitioners had already defrayed the transplanting expenses before respondent tendered the amounts.
- Whether the findings of fact by the Court of Agrarian Relations are supported by substantial evidence.
Ruling:
The Supreme Court affirmed the decision of the Court of Agrarian Relations, holding that:
- The findings of fact by the lower court are supported by substantial evidence.
- Petitioners failed to provide sufficient evidence to support their claims regarding the change to leasehold tenancy or their prior payment of transplanting expenses.
- The tender of transplanting expenses by respondent was made before the commencement of the transplanting season, and thus, respondent fulfilled her obligation.
Ratio:
Findings of Fact by the Court of Agrarian Relations:
- The Supreme Court reiterated the well-settled rule that the findings of fact by the Court of Agrarian Relations cannot be reviewed or reversed as long as there is substantial evidence to support them.
- In this case, the lower court's findings were fully supported by the evidence on record.
Burden of Proof:
- Petitioners failed to meet their burden of proving their claims regarding the change to leasehold tenancy and their prior payment of transplanting expenses.
Timeliness of Tender:
- The tender of transplanting expenses by respondent was made before the transplanting season began, which was sufficient to discharge her obligation under the tenancy agreement.