Facts:

This case involves Canuto Pagdanganan, the petitioner and landholder, who sought the ejectment of fifteen tenants from Barrio San Miguel, Guimba, Nueva Ecija, on the basis of violations of the provisions outlined in the Tenancy Law. The events leading to the petition occurred during the harvesting season of the agricultural year 1955-56. Pagdanganan accused the tenant respondents of reaping their palay crops without his knowledge or permission, failing to stack their harvest at the designated location, and appropriating loose grains for their personal gain without informing him of the amounts involved. In response, the tenants denied these allegations and counterclaimed for damages amounting to P2,300 due to the distress caused by the petition.

The lower court dismissed both Pagdanganan’s petition as well as the counterclaim for lack of merit and insufficiency of evidence. Pagdanganan then sought reconsideration, which was denied, prompting him to elevate the matter to the Supr

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Facts:

Background of the Case

• Canuto Pagdanganan, a landholder, filed a petition for ejectment against 15 of his tenants from Barrio San Miguel, Guimba, Nueva Ecija.
• The petition was filed before the Court of Agrarian Relations on the ground that the tenants violated provisions of the Tenancy Law.

Allegations Against the Tenants

• During the harvesting season for the agricultural year 1955-56, the tenants were accused of reaping their palay crops without the knowledge and permission of Pagdanganan or his authorized representatives.
• The tenants allegedly stacked their harvest in a location other than that designated by the landholder.
• It was further asserted that the tenants appropriated the loose grains for their personal use without informing the petitioner or his overseer about the precise amount harvested.

Response by the Respondents

• In their answer, the tenant-respondents denied the allegations contained in the petition.
• They counterclaimed, asserting that the filing of the petition caused them both actual and moral damages, and prayed for a dismissal of the petition along with an award of damages amounting to P2,300.00.

Trial Proceedings and Evidence Presented

• During the trial, the petitioner attempted to demonstrate that some tenants refused to sign tenancy contracts prepared by him.
• The lower court’s decision dismissed both the petition and the respondents’ counterclaim on grounds of lack of sufficient evidence and merit.
• Specifically, on the charge of unauthorized reaping, evidence only showed that the reaping took place without explicit permission—not that the tenants were not notified as required under Section 36 of Rep. Act 1199.

Pertinent Provisions of the Tenancy Law

• Section 36 of Rep. Act 1199 was cited, which provides that tenants have the right to determine when to reap the harvest provided that it is in accordance with proven farm practices and after due notice to the landholder.
• Section 39 of Rep. Act 1199 was also cited by the petitioner, stating that “it shall be unlawful for either the tenant or the landholder, without mutual consent to reap or thresh a portion of the crop at any time previous to the date set for its threshing.”
• The court clarified that section 39 applies only to the reaping of a portion of the crop before the entire harvest has been reaped, and was not applicable to the situation at hand.

Specific Incident Details

• Regarding the location for stacking the harvest, the lower court observed that the tenants chose a different site due to practical concerns (e.g., difficulty and potential damage due to a muddy pathway).
• Although the petitioner argued that as landholder he had the right to designate the site, the law under Section 37 of Rep. Act 1199 permits the landholder to propose a site subject to limitations, such as proximity (not farther than one kilometer from a majority-cultivated area) and the possibility for court intervention in cases of disagreement.
• On the allegation concerning the loose grains, the court found that the overseer’s refusal to liquidate them forced the tenants to bring them home to prevent loss or destruction, with the amount being verified by the barrio lieutenant, and that no damage was properly shown by the petitioner.

Additional Facts Related to Tenancy Contracts

• Some tenants refused to sign written tenancy contracts due to disagreements over the sharing basis in crop division.
• Such refusal was not considered a sufficient ground for dispossession under the enumerated provisions of Sec. 50 of Rep. Act 1199.

Issue:

Whether the absence of the landholder’s explicit prior knowledge or permission regarding the reaping of the harvest justifies ejectment under the Tenancy Law.

• Does mere lack of permission (as opposed to lack of notification) satisfy the legal requirement for ejectment?
• Is the action of the tenants in reaping consistent with the provisions of Section 36 of Rep. Act 1199?

Whether the tenants' decision to stack the harvest at a location different from that designated by the petitioner constitutes a breach warranting ejectment.

• Can the landholder exercise an absolute right to determine the site for stacking, despite the tenants’ objections and the procedural mechanism provided in Section 37 of Rep. Act 1199?
• Should court intervention be sought when there is a disagreement over the location, rather than unilateral action by the landholder?

Whether the appropriation of loose grains by the tenants, without informing the landholder, constitutes a violation of the Tenancy Law severe enough to ground ejectment.

• Does the act of taking the loose grains, which were later verified by the barrio lieutenant, justify the drastic remedy of dispossession?

Whether the refusal of some tenants to enter into a written tenancy contract can be considered as grounds for their ejectment.

• Is such refusal among the enumerated grounds for dispossession as established by Section 50 of Rep. Act 1199?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)