Title
Teodoro vs. Macaraeg
Case
G.R. No. L-20700
Decision Date
Feb 27, 1969
Landowner Teodoro dispossessed tenant Macaraeg, claiming civil lease and abandonment. Court ruled leasehold tenancy, no abandonment, awarded damages, upheld tenant rights.

Case Digest (G.R. No. L-20700)
Expanded Legal Reasoning Model

Facts:

  • Parties Involved:
    • Petitioner: Fidel Teodoro, the landowner.
    • Respondent: Felix Macaraeg, the alleged tenant.
    • Other Respondent: Jose Niegos, the new tenant placed by Teodoro.
  • Landholding in Dispute:
    • A 4-hectare riceland in Talugtug, Nueva Ecija, cultivated by Macaraeg for seven years.
  • Allegations by Macaraeg:
    • Macaraeg claimed to be a leasehold tenant of Teodoro.
    • On March 2, 1961, Teodoro informed Macaraeg that the landholding would be given to another tenant, Jose Niegos, on the pretext that Macaraeg was contracting to be a tenant elsewhere.
    • Macaraeg was prevented from working on the land by Niegos.
    • Macaraeg sought reinstatement and damages for dispossession.
  • Defense by Teodoro:
    • Teodoro denied that Macaraeg was his tenant, claiming the land was always leased under civil lease agreements.
    • He alleged that Macaraeg abandoned the land after the expiration of the lease contract in January 1961.
    • Teodoro leased the land to Niegos after Macaraeg allegedly abandoned it.
  • Court Proceedings:
    • The Court of Agrarian Relations ruled in favor of Macaraeg, ordering his reinstatement and awarding damages.
    • Teodoro appealed, arguing that the contract was a civil lease, not a tenancy agreement, and that Macaraeg had abandoned the land.

Issues:

  • Whether the "Contract of Lease" between Teodoro and Macaraeg established a leasehold tenancy relationship.
  • Whether Macaraeg abandoned the landholding, thereby terminating the tenancy relationship.
  • Whether the agrarian court erred in awarding damages to Macaraeg despite the late filing of his supplemental petition for damages.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court affirmed the decision of the Court of Agrarian Relations, with the modification that Macaraeg's earnings during dispossession should not be deducted from the damages awarded. The Court upheld the leasehold tenancy relationship between Teodoro and Macaraeg, rejected the claim of abandonment, and validated the award of damages.

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