Title
Cano vs. Cabangon
Case
G.R. No. L-12764
Decision Date
Dec 23, 1959
Tenants sought to change crop-sharing terms mid-contract; court upheld fixed 45-55 arrangement until 1959-1960, allowing changes thereafter.
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Case Digest (G.R. No. L-12764)

Facts:

Parties Involved:

  • Petitioners: Emilio Cano and 25 other tenants of Salvador de Jesus.
  • Respondents: Hon. Judge Domingo M. Cabangon and Salvador de Jesus (landholder).

Background:

  • The petitioners were tenants of Salvador de Jesus, cultivating rice lands in Concepcion, Tarlac, under a 45-55 crop-sharing arrangement.
  • In March 1956, the tenants petitioned the Court of Agrarian Relations to change their crop-sharing arrangement from 45-55 to 30-70, effective from the 1956-1957 agricultural year.

Contractual Agreements:

  • The tenants and the landholder had executed written contracts, registered as per Section 12 of Republic Act 1199.
  • The contracts stipulated a 45-55 division and included a provision stating that the agreement would remain in force as long as the tenancy relationship existed, unless amended by mutual agreement.
  • Additional stipulations in the contracts specified that the 45-55 sharing arrangement would apply for the agricultural years 1956-1957, 1957-1958, 1958-1959, and 1959-1960.

Landholder’s Opposition:

  • Salvador de Jesus opposed the tenants' petition, arguing that the written contract fixed the sharing arrangement until the 1959-1960 agricultural year.
  • He contended that the tenants' right to change the arrangement could only be exercised after the expiration of the contract period, as per Section 14 of Republic Act 1199 (as amended by Republic Act 2263).

Court’s Initial Decision:

  • The Court of Agrarian Relations authorized the change in the sharing arrangement but ruled that it would take effect only from the 1958-1959 agricultural year.
  • The tenants appealed, insisting that the change should apply from 1956-1957, as initially requested.

Issue:

  1. Whether the tenants had the right to change the crop-sharing arrangement before the expiration of the written contract period (1959-1960).
  2. Whether the stipulations in the written contract, particularly the fixed sharing arrangement for five years, were valid under Section 14 of Republic Act 1199.
  3. Whether the Court of Agrarian Relations erred in ordering the change to take effect only from 1958-1959 instead of 1956-1957.

Ruling:

The Supreme Court affirmed the decision of the Court of Agrarian Relations but clarified that the change in the crop-sharing arrangement could only take effect after the 1959-1960 agricultural year. The Court held:

  1. The written contract between the parties established a fixed sharing arrangement for five agricultural years (1956-1957 to 1959-1960).
  2. Section 14 of Republic Act 1199 permits such fixed-term arrangements, provided the tenancy relationship continues beyond the contract period.
  3. The tenants' right to change the sharing arrangement could only be exercised after the expiration of the five-year period specified in the contract.
  4. The Court found no error in the lower court’s decision, as it favored the tenants’ interests, and the landholder did not appeal.

Ratio:

  1. Validity of Fixed-Term Sharing Arrangements:

    • A written contract fixing a crop-sharing arrangement for a specific period (e.g., five years) is valid under Section 14 of Republic Act 1199.
    • Such stipulations do not bar the tenants’ right to change the arrangement after the expiration of the contract period.
  2. Tenants’ Right to Change Arrangement:

    • The right to change the crop-sharing arrangement under Section 14 can only be exercised after the expiration of the written contract period.
    • The tenancy relationship continues even after the contract expires, allowing tenants to demand a new arrangement thereafter.
  3. Equitable Considerations:

    • The landholder’s financial obligations to the hacienda owner were likely tied to the fixed sharing arrangement. Altering the arrangement mid-term would be inequitable without corresponding adjustments to the landholder’s obligations.
  4. Finality of Lower Court’s Decision:

    • Since the landholder did not appeal, the Court could not correct the error in the lower court’s decision to allow the change from 1958-1959.
    • The tenants’ appeal was dismissed, as the decision ultimately favored their interests.


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