Case Digest (G.R. No. L-39181)
Facts:
Delfin Jasmin v. Car Judge Miguel Valera, and Juan Badua, G.R. No. 39181, June 27, 1985, Supreme Court Second Division, Escolin, J., writing for the Court.Petitioner Delfin Jasmin was tenant-lessee since 1963 of a nine-hectare parcel owned by private respondent Juan Badua in Bintawan, Nueva Vizcaya. The yearly rental was fixed at 90 cavans of palay for five hectares of riceland and 20 sacks of husked corn for four hectares of cornland. On December 17, 1971, Badua filed CAR Case No. 236 NV-'71 in the Court of Agrarian Relations of Bayombong seeking ejectment on grounds of alleged subleasing without the owner’s consent, nonpayment of rentals, and planting of bananas on rice land without permission.
At pre-trial the parties, with counsel, entered into a compromise agreement dated February 20, 1973 in which Jasmin agreed to “voluntary surrender” of the landholding under specified terms: he would cultivate the land for the next main crop and keep the produce as consideration; Badua would condone Jasmin’s indebtedness (back rentals); and both parties agreed to be bound by the agreement. Judge Miguel Valera found the compromise not contrary to law or public policy and approved it, rendering a decision on March 29, 1973 based on that agreement.
Badua later filed a motion for execution (December 13, 1973) and for citation of Jasmin for contempt for refusing to vacate. After initial resolutions and a commissioner’s order directing enforcement, Jasmin was detained by the provincial constabulary in February 1974 and released on order of the judge. On February 23, 1974 Judge Valera denied the motion for execution and ordered Jasmin to be maintained as lessee; on reconsideration and upon Badua’s motion the judge reversed that resolution on May 8, 1974 and ordere...(Pro-only)
Issues:
- Is the compromise agreement whereby an agricultural lessee promises future surrender of the landholding void as a prohibited “future surrender” under Section 36 of Republic Act No. 6389 (Code of Agrarian Reforms)?
- Was petitioner’s alleged surrender involuntary or obtained by deception so as to void th...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)