Case Summary (G.R. No. L-49731)
Tenancy Agreements
In the agricultural year 1958-1959, Bermudez and Sampaga entered into tenancy contracts (Exhibits A and B) with Fernando. According to these contracts, the produce sharing system was established at 50% for each party, with Fernando responsible for the transplanting expenses. However, these contracts were not renewed for the subsequent agricultural year, 1960-1961.
Dispute Over Planting Expenses
In August 1960, the petitioners refused to accept the sums of P45.00 and P60.00 that Fernando offered them as coverage for their respective transplanting expenses. Following this refusal, on September 15, 1960, Fernando consigned these amounts with the Court of Agrarian Relations in Cabanatuan City, thereby seeking to compel acceptance of the sums as fulfillment of her obligation for the 1960-1961 agricultural year.
Notification of Tenancy Change
The petitioners contended that in January 1960, they informed Fernando of their intention to transition from share tenancy to leasehold tenancy according to Section 14 of Republic Act No. 1189, as amended. They argued that they had already borne the transplanting expenses prior to the amounts being tendered by Fernando.
Court Judgment
After reviewing the case, the court rendered a judgment that:
- Recognized that Fernando had effectively met her obligations for transplanting expenses for the agricultural year 1960-1961.
- Ordered the Clerk of Court to release the amounts consigned to Bermudez and Sampaga.
- Additionally, mandated Fernando to pay extra sums to both petitioners.
Evidence and Findings
The respondent court dismissed the petitioners' claim regarding their notice to change the tenancy system, citing a lack of sufficient evidence to substantiate their assertion. The court emphasized that no mention of this contention was made during the petitioners' testimonies. Regarding the transplanting expenses, the court affirmed that Fernando’s offer occurred prior to the start of the transplanting season, thus allowing her claim to be valid.
Legal Principles
The legal standard affirms that the findings of fact of the Court of Agrarian Relations are typically upheld unless there is a clear abse
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Case Background
- Petitioners: Angel Bermudez and Isabelo Sampaga, tenants of respondent Margarita Fernando.
- Location: Landholdings of respondent situated in barrio Sto. Nino Torcero, municipality of San Jose, Nueva Ecija.
- Tenancy Contracts: The petitioners entered into tenancy contracts (Exhibits A and B) for the agricultural year 1958-1959, stipulating a 50-50 sharing system for produce, with transplanting expenses to be covered by the respondent.
- Contract Status: The tenancy contracts were not renewed for the agricultural year 1960-1961.
Events Leading to the Dispute
- August 1960: Petitioners refused to accept P45.00 and P60.00 offered by the respondent for their transplanting expenses.
- September 15, 1960: The respondent consigned these amounts to the Court of Agrarian Relations (CAR Case No. 2188-NE'60) and sought to compel petitioners to accept payment for transplanting expenses for the agricultural year 1960-1961.
Petitioners' Claims
- Notification: Petitioners claimed they notified the respondent in Ja