Title
Bermudez vs. Ferdo
Case
G.R. No. L-18610
Decision Date
Apr 22, 1963
Tenants challenged landowner over transplanting expenses and leasehold conversion; court upheld landowner's compliance, citing insufficient evidence from tenants.
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Case Summary (G.R. No. L-18610)

Court of Agrarian Relations and Findings of Fact

  • The findings of fact made by the Court of Agrarian Relations are not subject to review or reversal if there is substantial evidence supporting them.
  • This principle is established in the case of Atayde vs. de Guzman, which emphasizes the deference given to the factual determinations of the Court of Agrarian Relations.

Background of the Case

  • Petitioners Angel Bermudez and Isabelo Sampaga are tenants of respondent Margarita Fernando, who owns landholdings in barrio Sto. Nio Torcero, San Jose, Nueva Ecija.
  • In the agricultural year 1958-1959, the petitioners entered into tenancy contracts (Exhibits A and B) with a sharing system of 50-50, with transplanting expenses to be borne by the respondent.
  • The contracts were not renewed for the agricultural year 1960-1961, leading to a dispute regarding the transplanting expenses.

Dispute Over Transplanting Expenses

  • In August 1960, the petitioners refused to accept amounts of P45.00 and P60.00 offered by the respondent for their planting expenses.
  • Consequently, on September 15, 1960, the respondent consigned these amounts with the Court of Agrarian Relations, seeking to compel the petitioners to accept them as fulfillment of her obligation.

Petitioners' Claims

  • The petitioners claimed they had notified the respondent in January 1960 of their desire to change their tenancy from sharehold to leasehold, as permitted by Section 14 of Republic Act No. 1199.
  • They also asserted that they had already incurred the transplanting expenses prior to the respondent's tender of payment.

Court's Findings and Judgment

  • The court found insufficient evidence to support the petitioners' claim regarding the change in tenancy system, noting that this contention was not mentioned during their testimonies.
  • Regarding the transplanting expenses, the court determined that the respondent's tender occurred before the transplanting season began, thus supporting the respondent's position.
  • The court ruled in favor of the respondent, declaring that she had fulfilled her obligatio...continue reading

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