Facts:

The case involves Eunaria B. Vda. de Guilas and several co-owners as petitioners against Ananias David, Rosallo Mercado, and Judge Pastor de Guzman of the Court of Agrarian Relations, Branch III, Fifth Regional District, as respondents. The events took place in the barrio of San Matias, Guagua, Pampanga, concerning a parcel of riceland that the petitioners co-owned. Since October 1962, Ananias David had worked as a tenant on the land. In 1963, David sold his "right to work" on the property to Rosallo Mercado without notifying the landowners. Subsequently, Mercado began to cultivate the land.

The landowners opposed this arrangement, leading them to enter into an agreement (referred to as Annex A) with David and Mercado on November 1, 1963. This agreement acknowledged that David had sold his rights illegally and outlined that Mercado would harvest only the current crop and return the land to the landowners after harvesting, allowing them to lease it to another tenant. De

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Facts:

Parties and Background

• Petitioners: A group of co-owners of a parcel of riceland located in the barrio of San Matias, Guagua, Pampanga.
• Respondents:
• Ananias David – the initial tenant who cultivated the land since October 1962.
• Rosallo (or Rosalio) Mercado – the individual who acquired David’s “right to work” in 1963 without the petitioners’ knowledge or consent, after which he began planting on the land.
• Additional party: The Honorable Pastor De Guzman, Judge, Court of Agrarian Relations, Branch III, Fifth Regional District, is also involved in the procedural history of the case.

The Transaction and Dispute Origin

• In 1963, David sold his tenant-right on the land to Mercado without procuring the petitioners’ consent.
• The petitioners, opposed to Mercado’s tenancy due to the unauthorized sale, objected to his presence on the land.

The Compromise Agreement (Annex A)

• On November 1, 1963, an agreement was executed (rendered in the Pampango dialect and translated into English) between petitioners, David, and Mercado.
• David admitted selling his right as tenant without authorization and agreed to surrender his work on the land.
• Mercado agreed to harvest only the present crop (to be harvested in January 1964) and, after the harvest, to return possession of the land to petitioners.
• Petitioners agreed to desist from litigating the matter by accepting the compromise despite their initial opposition to Mercado’s tenancy.
• The intention behind the compromise was not to validate a tenancy relationship, but rather to secure a promise from Mercado to vacate the land after the said harvest.

Litigation Proceedings and Developments

• On March 11, 1964, petitioners filed CAR Case No. 17-P-64 against David and Mercado for ejectment with an injunction, alleging Mercado’s failure to surrender the land after the crop was harvested in January 1964.
• Ananias David did not contest the complaint and was declared in default.
• Mercado filed an answer on May 8, 1964, admitting some allegations while denying others, and raised the following defenses:
• Assertion that he had informed an Eduardo Guilas about the land before he began work.
• Claim that Annex A did not reflect the true intent of the parties.
• Argument that an agreement on future surrender is not enforceable in law.
• At the pre-trial conference held on September 29, 1964, counsel for both sides agreed on a partial stipulation of facts, reserving the right to introduce further evidence later.
• On November 27, 1964, Mercado filed a motion to dismiss, contending that the contention for ejectment was based solely on the alleged agreement to surrender the land in the future—a ground not supporting a claim for ejectment.
• The Court of Agrarian Relations granted Mercado’s motion to dismiss, effectively dismissing the case, which led petitioners to elevate the issue for review.

Applicable Statutory Framework

• The decision under review relied on Section 50 of Republic Act No. 1199 (amended version, upon which Section 36 of Republic Act No. 3844 is based), which enumerates grounds upon which a land tenant may be dispossessed.
• The crucial point was that this provision would not apply if Mercado was not considered a tenant at the relevant time, given that David’s unauthorized sale did not bind the petitioners.

Issue:

Nature and Effect of the Compromise Agreement

• Whether the agreement (Annex A) executed by the parties constituted an enforceable compromise that bindingly terminated any tenancy, even though the petitioners originally opposed Mercado as a tenant.
• Whether the agreement created a valid landlord-tenant relationship whereby Mercado’s possession would be legitimized.

Enforceability of Future Surrender

• Whether the promise by Mercado to harvest the present crop and then surrender the land in January 1964 is enforceable as a basis for ejectment.
• Whether such an arrangement can be used to secure petitioners’ rights to reclaim possession in light of Mercado’s non-compliance.

Application of Statutory and Civil Code Provisions

• Whether Section 50 of Republic Act No. 1199, as amended, applies in a situation where a compromise agreement was executed, even if the initial sale of tenant-rights was unauthorized.
• Whether Article 2037 (on the binding effect of compromise as res adjudicata) and Article 2041 (authorizing enforcement of a compromise upon non-compliance) of the Civil Code support the petitioners’ claim.

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Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)