Facts:

In the case of Hijos de I. de la Rama v. Vicente Benedicto, the dispute arose from a rental agreement involving agricultural produce. The respondent, Hijos de I. de la Rama, filed a suit against the defendant, Vicente Benedicto, regarding the failure to deliver an agreed portion of the crop for the year 1899. Specifically, the plaintiffs claimed that Benedicto did not deliver a part of the rental share, which was stipulated to be an aliquot part of the crop, corresponding to one-fourth of the total yield. The testimony was provided by witnesses Felix Labayan, Casiana Capilar, and Timoteo Unson, who attested to Benedicto's failure to deliver as per their agreement. The issue was brought before the lower court, where it focused on whether the plaintiffs had the right to eject the defendant due to this failure. The trial court ruled in favor of the plaintiffs, affirming their right to take legal action for failure to deliver crop rents under the terms of their agreement, thus a

...

Facts:

Contractual Agreement and Rent Payment

• The parties involved were HIJOS DE I. DE LA RAMA (plaintiffs and appellees) and VICENTE BENEDICTO (defendant and appellant).
• The contract stipulated payment of rent through the delivery of an aliquot part of the crop (specifically, one-fourth of the crop).

Non-Delivery of the Crop

• Testimonies from Felix Labayan, Casiana Capilar, and Timoteo Unson established that a portion of the 1899 crop was not delivered by the defendant as required by the contract.
• The failure to deliver this aliquot part of the crop constituted a failure to pay the agreed rent under the contractual provisions.

Relevant Legal Provisions

• Article 1575 of the Civil Code was considered inapplicable to the situation because it does not address contracts where rent is paid as an aliquot part of the crop.
• Article 1569, section 2 was relevant as it provided the legal basis for the plaintiff’s right to eject the defendant due to the failure to pay rent.

Nature and Timing of the Suit

• The suit was brought solely for the purpose of ejecting the defendant on the grounds of non-payment of rent through non-delivery of the crop.
• Although the suit was initiated before the termination of the crop for 1899–1900, its commencement was appropriate since it was prompted by the defendant’s failure to deliver the crop at the time specified in the contract.

Defendant’s Counterclaim and Other Assertions

• The defendant’s purported counterclaim was rejected by the trial court and subsequently by the appellate court, as it lacked merit.
• The defendant argued that he had abandoned the land; however, no evidence in the record supported this claim, and the appellate decision noted that the plaintiff’s right to eject was unaffected by such an unsubstantiated allegation.

Issue:

Breach of Contract Through Non-Delivery

• Does the failure to deliver the required fraction of the crop amount to a breach of the contract by constituting non-payment of rent?
• Is such a breach sufficient to justify the plaintiff’s right to eject the defendant under article 1569, section 2?

Applicability and Interpretation of Legal Provisions

• Can article 1575 of the Civil Code be applied to excuse the incomplete performance of a contract where rent is paid with a crop share?
• Should the interpretation of the law distinguish between contracts with a fixed monetary rent and those with rent paid in kind (i.e., an aliquot part of the crop)?

Proper Filing of the Suit

• Is the filing of the suit for ejectment proper even when brought before the termination of the crop season?
• Does the timing of the suit affect the legitimacy of the claim for ejectment based on the defendant’s failure to deliver the crop?

Defendant’s Claim of Abandonment

• Would evidence of land abandonment by the defendant affect the court’s decision regarding the ejectment?
• Was the record sufficient to support or refute the allegation of abandonment?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)