Case Summary (G.R. No. 120363)
Procedural History
Petitioner instituted an ejectment action in the Municipal Trial Court (MTC) after Herminigildo refused to vacate. On September 17, 1992, the MTC ordered Herminigildo to vacate and awarded petitioner attorney’s fees (P10,000) and damages of P500 monthly from filing. The Regional Trial Court (RTC) set aside the MTC decision and remanded the case to the Department of Agrarian Reform Adjudication Board (DARAB) for further adjudication, reasoning that the tenancy relationship between Ana Pascual and petitioner had to be determined and that the son’s presence might be incident to the tenant’s rights. The Court of Appeals (CA) affirmed the DARAB’s determination that a tenancy relationship existed and that Herminigildo—an immediate farm household member—was entitled to protection and could not be treated as a common squatter; the CA therefore dismissed petitioner’s appeal. Petitioner sought review before the Supreme Court.
Issue Presented
Whether a member of a tenant’s immediate farm household (Herminigildo), who assists the tenant in cultivation but is not the tenant, is entitled under Republic Act No. 1199, as amended by R.A. No. 2263, to demand and maintain a separate home lot and construct and occupy his own house within the landholding.
Applicable Law and Constitutional Framework
Primary statutory provisions relied upon in the decision are Republic Act No. 1199 (as amended by R.A. No. 2263) — particularly Section 5(a) (definition of “tenant” and “immediate farm household”), Section 22(3) (right of the tenant to demand a home lot), and Section 2 (purpose of the Act). The decision was rendered in 1998 and therefore is applied under the 1987 Constitution of the Republic of the Philippines.
Statutory Interpretation Adopted by the Court
The Court applied the plain-meaning rule: the statute’s language is clear that the right to demand a home lot is vested in “the tenant.” Section 22(3) expressly confines the home-lot right to the tenant and prescribes a maximum area (not more than 3% of the landholding, up to 1,000 square meters) and conditions governing removal of the tenant’s dwelling. Because Herminigildo did not claim to be the tenant and admitted he was an immediate household member assisting his mother, the Court found the statutory grant of a home lot did not extend to him.
Policy Considerations and Legislative Purpose
The Court emphasized the Act’s declared purpose to establish equitable agricultural tenancy relations and to protect the rights of both tenants and landholders. It reasoned that permitting every member of an immediate farm household to claim a separate home lot (up to 1,000 sq. m. each) would convert productive farmland into residential clusters, frustrate equitable division of produce and income, and undermine efficient agricultural production—outcomes contrary to the statutory objectives. The Court also noted that Ana Pascual already had an existing home lot and house available for Herminigildo’s incidental use while attending to agricultural labor.
Facts Pertaining to the Occupation and Use
The Court observed that Herminigildo constructed a concrete house on petitioner’s small parcel without petitioner’s permission, thereby appropriating property use from the landholder without compensation. The Court found this conduct not merely incidental to tenancy-assistance, particularly given the tenant-mother’s available home and house and her infirmity that would reasonably require her children’s assistance.
Legal Conclusions and Reasoning on Protection of Parties
The Court concluded that assistance by immediate household members to the tenant in cultivation is protected insofar as it secures the tenant’s ability to farm, but that protection does not extend to conferring the tenant’s statutory privilege to demand and occupy a separate home lot. The Court reiterated that the
...continue readingCase Syllabus (G.R. No. 120363)
Case Citation and Procedural Posture
- Reported at 344 Phil. 375; 94 OG No. 24, 4278 (June 15, 1998).
- Third Division; G.R. No. 120363, September 05, 1997 (Supreme Court decision date as indicated in the source header).
- Petition for review on certiorari to the Supreme Court from the decision of the Court of Appeals (C.A.- G.R. SP. No. 34628, February 28, 1995).
- Parties: Petitioner — Cecilleville Realty and Service Corporation; Private Respondent — Herminigildo Pascual; Respondent — The Court of Appeals.
- Case originated as an ejectment action filed by petitioner in the Municipal Trial Court of Sta. Maria, Bulacan; appealed to the Regional Trial Court; remanded to the DARAB by the Regional Trial Court; appealed to the Court of Appeals; thereafter brought to the Supreme Court by petitioner.
Facts
- Petitioner Cecilleville Realty and Service Corporation is the registered owner of a parcel of land in Catmon, Sta. Maria, Bulacan, covered by Transfer Certificate of Title No. 86.494 (M).
- Private respondent Herminigildo Pascual occupies a portion of that land.
- Repeated demands by petitioner for private respondent to vacate were refused.
- Private respondent asserted entitlement to occupy the land because he helps his mother, Ana Pascual — who is the tenant of petitioner — to cultivate the land.
- Petitioner instituted ejectment proceedings against Herminigildo Pascual in the Municipal Trial Court of Sta. Maria, Bulacan.
- Ana Pascual cultivates a two (2) hectare parcel of land (as noted in the petitioner’s memorandum).
- It is undisputed for purposes of this petition that Ana Pascual is a bona-fide tenant of petitioner and that she may be assisted by members of her immediate farm household.
Municipal Trial Court Disposition
- On September 17, 1992, the Municipal Trial Court ordered private respondent Herminigildo Pascual to vacate the land.
- The Municipal Trial Court further ordered payment by private respondent of attorney’s fees in the amount of P10,000.00 and the payment of P500.00 monthly from the filing of the complaint.
Regional Trial Court Action
- The private respondent appealed to the Regional Trial Court.
- On April 4, 1994, the Regional Trial Court set aside the Municipal Trial Court’s decision and remanded the case to the Department of Agrarian Reform Adjudication Board (DARAB) for further adjudication.
- The Regional Trial Court reasoned that the tenancy relationship between petitioner and Ana Pascual must be addressed in the ejectment proceedings, and that Ana Pascual’s right to assistance from immediate farm household members (including her son) is protected by law; ejecting Herminigildo would effectively deprive Ana Pascual of that assistance.
DARAB Proceedings and Findings (as reported)
- DARAB rendered a Decision of November 8, 1993 (as referenced by the Court of Appeals) which ordered petitioner to respect and maintain the peaceful possession and cultivation of the property by defendant Ana Pascual and ordered the execution of an agricultural leasehold contract between the parties.
- DARAB’s decision was relied upon by the Court of Appeals in finding that a tenancy relationship and the tenant’s security of tenure existed.
Court of Appeals Decision
- The Court of Appeals dismissed petitioner’s appeal and affirmed the lower pronouncements that private respondent could not be ejected as a mere squatter because a tenancy relationship existed between Ana Pascual and petitioner.
- The Court of Appeals traced the tenancy to 1976 when Sotero Pascual (private respondent’s father) became the tenant of Jose A. Resurreccion, President of Cecilleville Realty and Service Corporation; tenancy continued until Sotero’s death in 1991 and succeeded by his wife Ann Pascual by operation of law.
- The Court of Appeals applied Section 5(a) of Republic Act No. 1199, as amended by RA 2263, defining “tenant” and “immediate farm household,” and concluded that Herminigildo, although not the tenant, is protected because he is a member of his mother’s immediate farm household and his mother is old and infirm.
- The Court of Appeals held: “His having a house of his own on the property is merely incidental to the tenancy,” and affirmed the disposition of the case below with costs against petitioner.
Issue Presented to the Supreme Court
- Petitioner’s lone assignment of error: whether the Court of Appeals erred in not finding that, while private respondent is entitled to work on the agricultural land of petitioner in his capacity as member of the family of tenant Ana Pascual, he cannot occupy a substantial portion of the land and utilize the same for residential purposes.
- The Supreme Court framed the dispositive legal question as the proper interpretation of Section 22, paragraph 3 of Republic Act No. 1199, as amended by Republic Act No. 2263, concerning the tenant’s right to a home lot.
Relevant Statutory Provision (Section 22(3), R.A. No. 1199, as amended by R.A. No. 2263)
- The Supreme Court quoted Section 22, paragraph 3 in full as provided in the source:
- “SEC. 22 . . . (3) The tenant shall have the right to demand for a home lot suitable for dwelling with an area of not more than 3 per cent of the area of his la