Case Summary (G.R. No. 145568)
Antecedents
Esteban Pollescas was the original tenant of the land until his death in 1991, at which point his son Enrique Pollescas was appointed as the tenant by the Tan Heirs. However, Reynalda Pollescas asserted her right as the successor tenant. The Tan Heirs refused to recognize this claim, leading Reynalda to file a complaint with the Department of Agrarian Reform Adjudication Board (DARAB-Ozamis) for the annulment of previous agreements and tenancy relationship resolutions. The DARAB declared Reynalda as the lawful tenant and apportioned the harvests according to a customary sharing system. Disagreements arose when Reynalda failed to deliver the agreed share of the harvests to the Tan Heirs.
Subsequent Legal Proceedings
Reynalda’s non-compliance prompted the Tan Heirs to file a criminal complaint for estafa against her, resulting in her conviction and a sentence requiring restitution of the unpaid rental amount. Thereafter, the Tan Heirs initiated an ejectment case against Reynalda with DARAB-Misamis Occidental, which initially ruled in favor of the Tan Heirs, ordering her ouster from the land. Reynalda appealed, and the DARAB in Diliman reversed the decision, requiring the Tan Heirs to accept Reynalda's continued possession. The Tan Heirs subsequently escalated the matter to the Court of Appeals, which upheld the DARAB's ruling.
Ruling of the Court of Appeals
The Court of Appeals affirmed the DARAB's decision, referencing established jurisprudence that non-payment or partial payment by a tenant does not automatically justify eviction unless it demonstrates willful intent to default. It reasoned that Reynalda's failure to deliver the full share was not indicative of an intent to defraud, especially amidst legal proceedings concerning her tenancy rights. Furthermore, the court clarified that the legality of the rental amount is pivotal for eviction claims, emphasizing that any lease rental exceeding the legal maximum of 25% of harvests under Republic Act No. 3844 is deemed unlawful.
Legal Framework and Analysis
The applicable laws include Republic Act No. 6657, which governs agrarian reform, specifically recognizing agricultural leasehold tenants' security of tenure. The management of leasehold relationships is governed by guidelines that delineate valid grounds for dispossession, largely protecting tenants except in instances expressly detailed in Section 36 of RA 3844. The appellate court underscored that any claim for rental must align with legal parameters; hence, the Tan Heirs' assertion of a 2/3 share rental was contrary to the prescribed legal limit.
Issues Raised by Petitioners
The Tan Heirs raised two primary issues regarding whether the grounds for leasehold relation termination were satisfied a
...continue readingCase Syllabus (G.R. No. 145568)
Overview of the Case
- The case is a petition for review by the Heirs of Enrique Tan, Sr. against Reynalda Pollescas concerning possession and cultivation rights over a coconut farmland located in Labo, Ozamis City.
- The Court of Appeals affirmed the decision of the Department of Agrarian Reform Adjudication Board (DARAB), which ordered the Tan Heirs to respect Reynalda's possession and cultivation of the land.
- The case was promulgated on November 17, 2005, under G.R. No. 145568.
Antecedents
- The Tan Heirs, consisting of Norma Tan, Jeanette Tan, Julieta Tan, Rommel Tan, and Enrique Tan, Jr., are co-owners of a 25,780 square meter coconut farmland.
- Esteban Pollescas was the original tenant of the land, succeeded by his son Enrique Pollescas upon Esteban's death in 1991.
- Reynalda, Esteban's surviving spouse, claimed tenancy rights after disputing Enrique's appointment and subsequently filed a complaint with the DARAB.
- On April 28, 1993, DARAB-Ozamis declared Reynalda the lawful tenant and apportioned the harvests, stipulating a customary sharing system (2/3 to the landowner and 1/3 to the tenant).
Events Leading to Dispute
- Reynalda failed to deliver the agreed share of the harvests to the Tan Heirs, leading to their complaint for estafa in the Municipal Trial Court.
- The trial court found Reynalda guilty and sentenced her to imprisonment while ordering her to