Facts:

The case involves Cecilleville Realty and Service Corporation as the petitioner and Herminigildo Pascual as the private respondent. The events transpired in Catmon, Sta. Maria, Bulacan, where the petitioner owned a parcel of land covered by Transfer Certificate of Title No. 86.494 (M). Herminigildo Pascual occupied a portion of this land, claiming entitlement to it as he assisted his mother, Ana Pascual, who was the tenant of the property. Despite repeated demands from the petitioner for Herminigildo to vacate the premises, he refused, leading the petitioner to file an ejectment suit against him in the Municipal Trial Court of Sta. Maria, Bulacan. On September 17, 1992, the Municipal Trial Court ruled in favor of the petitioner, ordering Herminigildo to vacate the land and pay attorney's fees amounting to P10,000.00, along with P500.00 monthly from the filing of the complaint. Herminigildo appealed this decision to the Regional Trial Court, which on April 4, 1994, overtur...

Facts:

Ownership and Occupation:

• Petitioner Cecilleville Realty and Service Corporation owns a parcel of land in Catmon, Sta. Maria, Bulacan, covered by T.C.T. No. 86.494 (M).
• Private respondent Herminigildo Pascual occupies a portion of this land.

Tenancy Claims:

• Herminigildo Pascual claims he is entitled to occupy the land because he is assisting his mother, Ana Pascual, who is allegedly a tenant of the petitioner.
• Despite repeated demands, Herminigildo refused to vacate the land.

Legal Proceedings:

• Petitioner filed an ejectment suit against Herminigildo Pascual before the Municipal Trial Court (MTC) of Sta. Maria, Bulacan.
• The MTC ruled in favor of the petitioner, finding no tenancy relationship between the petitioner and Herminigildo Pascual. The court ordered Herminigildo to vacate the land and pay attorney’s fees and monthly compensation.

Appeal to the Regional Trial Court (RTC):

• Herminigildo appealed to the RTC, which set aside the MTC’s decision and remanded the case to the Department of Agrarian Reform Adjudication Board (DARAB) for further adjudication.
• The RTC held that Ana Pascual, as a tenant, had the right to seek assistance from her immediate farm household, including her son Herminigildo.

Court of Appeals Decision:

• The Court of Appeals affirmed the RTC’s decision, ruling that Herminigildo Pascual, as a member of Ana Pascual’s immediate farm household, was entitled to work on the land and maintain his residence there.

Issue:

• (Unlock)

Ruling:

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Ratio:

1. Statutory Interpretation:

   • The law is clear that only the tenant is granted the right to a home lot and the right to construct or maintain a house on the land. The term "immediate farm household" does not extend the right to a home lot to non-tenants.
   • The Court emphasized that the law must be applied according to its plain and obvious meaning, and there should be no departure from its express terms.

2. Purpose of Tenancy Laws:

   • The purpose of Republic Act No. 1199 is to establish agricultural tenancy relations based on social justice, ensuring equitable division of produce and income, and promoting efficient agricultural production.
   • Allowing non-tenants to occupy and build houses on the land would undermine the productivity of the land and the purpose of the tenancy laws.

3. Protection of Landholder’s Rights:

   • The Court noted that the landholder is also entitled to protection under the law. Granting Herminigildo Pascual the right to maintain his own house would deprive the landholder of their property without compensation.
   • The Court rejected the argument that Herminigildo’s occupation of the land was merely incidental to the tenancy, emphasizing that such an interpretation would lead to the conversion of agricultural land into residential use, contrary to the law’s intent.

4. Social Justice and Compassion:

   • While the Court acknowledged the principle of social justice, it clarified that compassion for the poor does not extend to granting undeserved privileges. Herminigildo Pascual’s claim to a home lot was not supported by law, and his occupation of the land was deemed improper.

Conclusion:

The Supreme Court granted the petition, reversing the Court of Appeals’ decision and reinstating the MTC’s ruling. Herminigildo Pascual was ordered to vacate the land and pay the petitioner attorney’s fees and monthly compensation. The Court emphasized that only the tenant, Ana Pascual, is entitled to a home lot, and non-tenants, even if members of the tenant’s immediate farm household, do not have the right to occupy or build on the land.