G.R. No. L-28090 - Dequito vs. Llamas

Petitioner Clemente Dequito filed a complaint for “Reliquidation and Damages” against respondent Victoria Llamas, alleging an inequitable sharing of produce arising from an agricultural tenancy.
The tenancy involved a one-hectare landhold seeded to one cavan of lowland palay, with an additional one‐half hectare also cultivated under similar sharing arrangements, located at Sitio Camansi, Hinigaran, Negros Occidental.
Under the arrangement, the produce was divided equally (50-50), while for a bamboo crop planted along the tenancy, the petitioner was entitled to 10% of the gross sale.

Petitioner contended that from the crop year 1964 onward, he was underpaid an amount (P62.34) due as his share from the bamboo sales.
It was also alleged that after crop year 1961-62, the respondent wrongfully dispossessed him of part of his landholding.
Petitioner further claimed that he incurred losses from cash loans he obtained from the respondent, alleging the loans carried usurious interest calculated in the form of palay.
Additional claims sought included:

Payment for short sharing of produce for six years with 8% legal interest,
Compensation for failure to plant in specific crop years,
Recovery of amounts improperly adjusted or overpaid in connection with cash loans,
Award of corrective (or exemplary) damages, moral damages, and attorney’s fees.

Initially, the respondent moved to dismiss the complaint on the principal ground that the petitioner had voluntarily surrendered his tenancy rights.
Petitioner executed a sworn affidavit dated June 1, 1967, in which he admitted:

That “the liquidation and the sharing basis was in accordance with law,” and
That he had received P700.00 from the respondent as full payment in consideration for the improvements and the surrender of his landholding.

A supporting document, a certification dated May 30, 1967, attested that the petitioner received P700.00 in full and complete payment for his voluntary surrender of the landholding.
The petitioner, in his subsequent motions, argued that his affidavit should not be construed as a waiver of his tenant rights, contending that such a waiver would contravene Article 6 of the New Civil Code, which protects against waivers that are contrary to law or public policy.

The respondent Court of Agrarian Relations ruled that the sworn statement was a valid acknowledgment and that the petitioner’s actions amounted to a voluntary surrender of his tenancy rights.
It was held that any issues regarding alleged usurious interest on loans should be subject to a separate litigation, requiring appropriate signed receipts or memoranda under Sec. 20 of Act 3844.
The petitioner’s motion for reconsideration was denied, reaffirming that the waiver was voluntarily executed and binding.

The affidavit was executed in a dialect familiar to the petitioner, ensuring that he fully understood the contents and legal consequences of his declarations.
Key statements in the affidavit included:

The petitioner never questioned the authenticity or voluntariness of this affidavit at the time of execution.

Whether the petitioner’s execution of the affidavit, which declared that the sharing basis was “in accordance with law” and that he had no further claim against the respondent, effectively amounted to a waiver of his tenant rights.
Whether the voluntary surrender of the landholding, evidenced by the affidavit and the certificate of receipt for P700.00, is conclusive and binding even if the petitioner later claimed a miscalculation in the benefits derived from that surrender.
Whether a waiver of rights expressed in a sworn statement can be invalidated by subsequent assertions of regret, miscalculation, or allegations of coercion, especially when no clear evidence supports such claims.
Whether the alleged issue of usurious interest on the cash loans—raised in the petitioner’s complaint—should be considered within the same litigation or treated as an independent matter subject to separate evidentiary requirements.