Case Digest (G.R. No. 190276)
Facts:
Eufrocina Nieves, as represented by her attorney-in-fact, Lazaro Villarosa, Jr., vs. Ernesto Duldulao and Felipe Pajarillo, G.R. No. 190276, April 02, 2014, Supreme Court Second Division, Perlas-Bernabe, J., writing for the Court. Petitioner Eufrocina Nieves is the registered owner of about six hectares of rice land in Dulong Bayan, Quezon, Nueva Ecija (the subject land). Ernesto Duldulao and Felipe Pajarillo were agricultural lessees and cultivators of the subject land who, under their lease, were to pay leasehold rentals of 45 cavans of palay each cropping season (May and December).Claiming accrued defaults in rentals since 1985 (alleged arrears of 446.5 cavans for Ernesto and 327 cavans for Felipe), petitioner filed a petition for ejectment with the Department of Agrarian Reform Adjudication Board — Provincial Adjudicator (PARAD) on March 8, 2006, for nonpayment of rentals. Before filing, a 2005 mediation before the Municipal Agrarian Reform Office produced admissions by respondents of some defaults and promises to pay. In their answers, Ernesto said he inherited some arrears but proposed four installment payments starting May 2006; Felipe denied incurring arrears but offered six installments starting May 2006. Both attributed nonpayment to calamities (flashfloods, typhoons).
In a Decision dated July 6, 2006, the PARAD found respondents willfully and deliberately in default and ordered their ejectment, holding that lease obligations survive the death of a prior leaseholder (rejecting Ernesto’s argument that his father’s death extinguished obligations). The DARAB later deputized the Provincial Sheriff and Municipal Agrarian Reform Officer (April 16, 2007) to supervise harvest; when implemented April 27, 2007, the harvest was already completed and proceeds had been used to pay other indebtedness.
On December 13, 2007, the DARAB affirmed the PARAD Decision, again finding willful and deliberate default justifying ejectment. Respondents appealed to the Court of Appeals (CA). In a Decision dated June 4, 2009, the CA granted respondents’ petition, reversing the DARAB: although it found defaults, the CA concluded the defaults were not deliberate and that respondents had substantially complied (quantifying Felipe’s unpaid share at 293 cavans or 16.28% and Ernesto’s at 107.5 cavans or 6%), relying on De Tanedo v. De La Cr...(Subscriber-Only)
Issues:
- Did the Court of Appeals correctly reverse the DARAB’s decision ordering the ejectment of respondents for nonpayment of leasehold rent...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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