G.R. No. 170498 - Metropolitan Bank and Trust Co. vs. Absolute Management Corp.

Lino Sales and Visitacion Salud Sales are the petitioners/appellants.
Maximo Macatangay is the respondent/tenant involved in the dispute.
Santiago Villalobos is introduced as a new tenant after the dismissal of Maximo Macatangay.

Maximo Macatangay had been the tenant of the petitioners since 1939.
In April 1955, Maximo was removed as tenant; subsequently, in May 1955, the land was handed over to Santiago Villalobos.
Dissatisfied with his removal, Maximo initiated legal action seeking reinstatement as tenant and damages.

On April 18, 1955, Maximo filed an action against the petitioners for his reinstatement and damages in the Court of Industrial Relations (CIR Case No. 5674-R).
With the creation of the Court of Agrarian Relations under Republic Act 1267 (as amended by Republic Act 1409), the case was transferred to the Agrarian Court.
The Agrarian Court issued a judgment ordering the petitioners to (a) reinstate Maximo as tenant on the contested land and (b) pay him P482.10 equivalent to his 60 percent share of the harvest from April 8, 1955, until his reinstatement.
A writ of execution was subsequently issued on November 28, 1956, and served on petitioners on December 13, 1956.

Although the writ of execution was carried out—evidenced by the payment of P482.10 to Maximo—the actual reinstatement of Maximo was delayed.
Santiago Villalobos had been actively cultivating the land by planting rice, with a standing crop split into two varieties scheduled for harvest in January and March 1957.
A verbal agreement was reached among Maximo, petitioners, and Villalobos:

Maximo’s reinstatement as tenant would be deferred until after the respective harvests of Villalobos’ crop.
Petitioners were obligated to notify Maximo of the harvest dates and reinstate him thereafter.

Relying on this agreement, Maximo refrained from taking immediate possession of the land post-execution.

After the harvest periods (January and March 1957), petitioners claimed that Maximo had abandoned the land by failing to take possession and cultivate it during the agricultural period from January to April 1957.
On this basis, the petitioners promptly filed a petition (CAR Case No. 103, Batangas 1957) before the Agrarian Court to eject Maximo from the landholding.
Maximo, however, contended that the agreement postponed his reinstatement until after the harvest, and therefore he could not be said to have abandoned land that he had not yet been given actual possession of.

The Court found that, although the writ of execution reinstated Maximo legally on December 13, 1956, his actual possession of the land was never effected due to the agreement to wait until after the harvest.
It held that abandonment as a ground for ejectment requires actual physical possession which Maximo never acquired.
Evidence was presented that Maximo visited the land in April 1957 to prepare it for cultivation, underscoring that he did not abandon his interest in the property.
The Agrarian Court thus concluded that Maximo could not be held to have abandoned the landholdings, as the requisite condition of previous possession was missing.

Whether the petitioners are entitled to eject Maximo Macatangay from the land based on the allegation of abandonment.
Whether the verbal agreement delaying reinstatement negates the claim of abandonment due to the lack of actual possession.
Whether the findings of the Agrarian Court, which rested on the absence of actual reinstatement and thus possession, are supported by substantial evidence.