G.R. No. L-2797 - Iturralde vs. Garduno

Plaintiff: Jose Iturralde, who filed the action against Defendant Antonio Garduno.
Nature of the dispute: Nonpayment of rentals for the years 1902 and 1903 for the occupation of a parcel of land.
Reference to a previous case: The issue pertaining to the nonpayment of rentals is noted as identical to that resolved in Iturralde vs. Magcauas (Case No. 2625), which had been decided in favor of the plaintiff.

The defendant was contractually obligated to pay a rental of 1 peso and 50 cents, as stipulated in the original lease.
This obligation, though outstanding, was separately recognized and is to be paid notwithstanding the subsequent rental adjustment for later years.

The court found that the defendant failed to fulfill his obligation to pay a just and reasonable rent for the occupation of the land during 1903.
The plaintiff claimed a rental of 9 pesos per annum for 1903, which was determined as just and reasonable based on the facts presented.
The judgment directs that this adjusted rent of 9 pesos per annum applies for the succeeding years until the judgment is executed.

In his testimony, the defendant stated that his rental obligation was inherited from his ancestors, claiming he was bound by the same contractual terms that had been contracted generations earlier with respect to the owner of the hacienda.
The defendant maintained that he did not pay more than 1 peso and 50 cents because that was the sole obligation his ancestors had originally contracted.
He argued that, under the specific condition in the contract (which he claimed to have been proven), rental adjustments were not permissible and, as long as he paid the stipulated rent punctually, he could not be ousted from the property.
Additional evidence presented by the defendant included:

Mention of improvements on the property such as a house valued at 550 pesos and the planting of fruit trees.
The suggestion that such improvements implied an indefinite lease or long duration, relying on the notion that the lease duration was left to the tenant’s will.

The defendant’s evidence largely rested on hearsay; his testimony centered on inherited obligations and did not provide firsthand evidence regarding the actual terms of the old contract.
The testimony of the defendant’s other witness (a tenant on the plaintiff’s hacienda) failed to elaborate on or corroborate the specific contractual details regarding the defendant.
The court noted that:

The contract in question was more than fifty years old, rendering personal recollection or verification by the defendant improbable.
The nature and timing of the contract did not support the notion that the lease's duration could be varied on the basis of improvements or the tenant’s will.

Whether the defendant should be compelled to pay a just and reasonable rent for the occupation of the land during 1903.
If so, what the just and reasonable amount should be, in light of the previous decision in Iturralde vs. Magcauas.

Whether it was proven that the lease included a condition stipulating that the rental of 1 peso and 50 cents per annum was fixed and could not be adjusted.
Whether the defendant’s reliance on the inherited obligation and the condition that allowed him to deprive the contract’s duration to his own discretion is legally tenable.

Whether the construction of a house and planting of fruit trees, and their respective economic values, could reasonably imply that the lease was of an indefinite term and subject to the tenant’s preferences.