G.R. No. 145568 - Heirs of Tan, Sr. vs. Pollescas

This case is a petition for review from the decision of the Court of Appeals (CA-G.R. SP No. 48823) issued on 31 August 2000.
The petitioners are the heirs of Enrique Tan, Sr. (Norma Tan, Jeanette Tan, Julieta Tan, Rommel Tan, and Enrique Tan, Jr.), collectively known as the Tan Heirs, who co-own a coconut farmland of 25,780 square meters located at Labo, Ozamis City.
Respondent Reynalda Pollescas, who is the surviving spouse of Esteban Pollescas, was involved in a dispute regarding her right of possession and cultivation over the land.

Esteban Pollescas was the original tenant of the Land. Upon his death in 1991, his son Enrique Pollescas succeeded him and was appointed as tenant by landowner Enrique Tan.
Reynalda Pollescas, as Esteban’s surviving second spouse, claimed succession as tenant. When Tan did not recognize her claim, she initiated proceedings before the Department of Agrarian Reform Adjudication Board in Ozamis City (DARAB-Ozamis).

In a DARAB-Ozamis decision dated 28 April 1993, Reynalda was declared the lawful tenant, with the harvest shares apportioned under the customary sharing system (2/3 to the landowner and 1/3 to the tenant).
On several harvest dates in 1993, Reynalda failed to deliver to the Tan Heirs their 2/3 share amounting to P3,656.70. Consequently, the Tan Heirs filed a criminal complaint for estafa with the Municipal Trial Court in Ozamis City.
The trial court found Reynalda guilty of estafa and sentenced her accordingly, additionally ordering her to pay the misappropriated amount.

Following Reynalda’s continued failure to deliver the required share, the Tan Heirs filed an ejectment case with DARAB-Misamis Occidental.
On 18 September 1996, DARAB-Misamis Occidental ruled in favor of the Tan Heirs by ordering Reynalda to vacate the land.
Reynalda subsequently appealed this ruling before DARAB Diliman in Quezon City, which reversed the ejectment decision. The new decision mandated that the Tan Heirs respect Reynalda’s peaceful possession and cultivation, while also ordering Reynalda to pay her unpaid leasehold rentals.
The Tan Heirs then elevated the case to the Court of Appeals, which affirmed the decision of DARAB Diliman. This led to the present petition for review before the Supreme Court.

Whether an exception exists to the grounds for extinguishment of the leasehold relation under Section 8 of RA 3844.

Specifically, whether failure by a tenant to pay a share that exceeds the legal limit may serve as a valid basis for ejectment.

Whether the Court of Appeals correctly ruled that Reynalda is obliged to pay only 1/4 or 25% of the normal harvest as lease rental instead of the 2/3 share demanded by the Tan Heirs, especially considering that the land was not yet formally placed under the leasehold system pursuant to Section 12 of RA 6657.