Case Digest (G.R. No. L-19735)
Facts:
Trinidad Yaptangco Vda. de Tizon v. Domingo M. Cabangon, as Judge of the Court of Agrarian Relations, Third Regional District, and Romualdo David, G.R. No. L-19735, January 23, 1967, the Supreme Court En Banc, Sanchez, J., writing for the Court.In 1942 respondent Romualdo David became tenant of two separate ricelands owned by petitioner Trinidad Yaptangco Vda. de Tizon: one in Barrio San Bartolome, Sto. Tomas, Pampanga (2.0853 ha) and another in Sto. Tomas, Pampanga (two lots totaling 2.3662 ha). Until 1959 the farms were managed by Ursula Raquis; thereafter petitioner took direct management. Prior sharing had been 55% to the tenant and 45% to the landholder.
On February 8, 1960 David filed a verified petition in the Court of Agrarian Relations (CAR) seeking, inter alia, reliquidation of the 1959–1960 harvest on the basis of increased tenant shares (62.5%–37.5% for San Bartolome and 70%–30% for Sto. Tomas) and reliquidation for earlier crop years (1954–55 through 1958–59) on specified bases. The CAR issued an interlocutory order directing deposit of portions of the 1959–60 harvest and delivery of shares to the parties; the deposit (Gomez Rice Mill Receipt No. 3943) was placed with the CAR and the order implemented.
After trial, the CAR (Feb. 8, 1962) held San Bartolome to be second class rice land and Sto. Tomas first class, and fixed the 1959–60 sharing at 62.5%–37.5% (San Bartolome) and 70%–30% (Sto. Tomas). The CAR granted reliquidation for 1956–57, 1957–58 and 1958–59 in those proportions, but denied reliquidation for 1954–56 insofar as barred by Section 17(3) of the Agricultural Tenancy Act. On motion, the CAR (Apr. 13, 1962) modified its reliquidation for the Sto. Tomas land for the years 1956–59 to 57.5%–42.5% (tenant’s favor) for certain years, and otherwise maintained its judgment. The landholder appealed.
The appeal reached the S...(Subscriber-Only)
Issues:
- For classification under the Agricultural Tenancy Act (R.A. 1199), must separate ricelands held by the same tenant be aggregated into one unit or treated separately for purposes of determining first- or second-class status?
- Was the CAR correct in changing the 1959–1960 sharing ratios (62.5%–37.5% and 70%–30%) despite the tenant’s notice timing and prior performance of some work, or does Section 14 of the Act bar such change until the end of the agricultural year (or next year)?
- Can petitioner avoid reliquidation for prior crop years by ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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