Title
Malate vs. Court of Appeals
Case
G.R. No. 55318
Decision Date
Feb 9, 1993
The Supreme Court upheld the recognition of petitioners as legitimate tenants, mandating their reinstatement and the payment of harvest shares.
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Case Digest (G.R. No. 55318)

Facts:

  • Petitioners: Angeles Malate, Norberto Esguerra, and Benedicto Esguerra.
  • Respondents: Honorable Court of Appeals and Felino Gemanil.
  • Original landowner: Feliciana Bautista, who instituted tenants Francisco Esguerra and Artemio Gonzales in 1939.
  • In 1961, Norberto and Benedicto Esguerra became tenants with Bautista's consent due to their father's old age.
  • Angeles Malate was also instituted as a tenant by Gonzales with Bautista's consent.
  • Agreement established a 75-25 sharing basis favoring petitioners for produce (pineapple, papaya, banana, rice).
  • Petitioners consistently delivered the landowner's share until Bautista's death.
  • After Bautista's death, her sister Matea Bautista managed the land, and petitioners continued their obligations.
  • In 1976, Felino Gemanil proposed a new agreement to plant sugarcane, offering a 15% share of the gross harvest.
  • Gemanil failed to honor the agreement and refused to reinstate the petitioners as tenants.
  • Petitioners filed a complaint with the Court of Agrarian Relations, which ruled in their favor on March 12, 1980.
  • The Court of Appeals reversed this decision on August 5, 1980, prompting the petitioners to appeal to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the petitioners.
  • The decision of the Court of Appeals was reversed, and the ruling of the Court of Agrarian Relations was reinstated.
  • The Supreme Court fo...(Unlock)

Ratio:

  • The Supreme Court emphasized that the appellate court's role is limited to assessing whether the agrarian court's findings are supported by substantial evidence.
  • Substantial evidence i...continue reading

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