Case Digest (G.R. No. L-21550)
Facts:
Alfredo Diaz v. Luis Molina, Narciso Maderia and The Honorable Jose M. Santos, Presiding Judge of the Court of Agrarian Relations, Second Regional District, Cabanatuan City, G.R. No. L-21550. April 27, 1967, Supreme Court En Banc, Zaldivar, J., writing for the Court.
Petitioner-appellant Alfredo Diaz (landholder) and respondents-appellees Luis Molina and Narciso Maderia (tenants) were parties to separate share-tenancy arrangements covering two-and-one-half hectare ricelands each in Barrio Bucot, Aliaga, Nueva Ecija; Judge Jose M. Santos was the presiding judge of the Court of Agrarian Relations (CAR), Second Regional District. Prior to the agricultural year 1961–1962 the parties followed a customary share-tenancy practice: the landholder paid transplanting expenses while the tenants supplied labor, draft animals and implements and the net harvest was shared fifty–fifty. The tenancy agreements were unwritten.
Before March 20, 1961 the tenants sought to convert their tenancy from share tenancy to leasehold beginning the agricultural year 1961–1962 (which began in late May 1961): they offered to assume all production expenses while the landholder would supply only the land. The landholder refused. In March 1961 the tenants filed petitions with the CAR seeking judicial approval of the change under Section 14 of Republic Act No. 1199; these were docketed as CAR Cases Nos. 2453-NE-61 and 2456-NE-61.
On August 7, 1961 the landholder filed CAR Case No. 2764-NE-61, depositing P100.00 (P50.00 for each tenant) representing the expenses for transplanting for 1961–1962 and offering P43.00 for seedlings (allocated between the tenants), asking the court to order withdrawal. On December 27, 1961 the landholder filed CAR Case No. 2834-NE-61 seeking ejectment of tenant Molina for alleged pre-threshing and negligence in violation of Section 39 of R.A. 1199. Each respondent filed answers in the respective cases.
The CAR heard the four matters together and, on March 18, 1963, rendered a consolidated judgment: it declared the tenancy relationship to be leasehold effective 1961–1962; fixed annual rentals for Molina and Maderia for specified agricultural years; ordered refunds to each tenant for specified quantities of palay (or their monetary equivalents); directed the Provincial Treasurer to release proceeds of sale of disputed harvest portions for 1962–1963; and dismissed the consignation and ejectment petitions (CAR Cases Nos. 2764-NE-61 and 2834-NE-61). The landholder’s motion for reconsideration was denied. Thereafter the landholder filed a notice of intention to appeal and, on July 13, 1963, filed the present petition for certiorari ...(Subscriber-Only)
Issues:
- Is Section 14 of Republic Act No. 1199 constitutional insofar as it grants tenants the right to change their contract from share tenancy to leasehold te...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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