Title
Pineda vs. Cabangon
Case
G.R. No. L-14502
Decision Date
Jun 30, 1961
Landowner Pineda sought to evict tenant Tiamzon, alleging neglect and failure to adopt farming methods. Courts ruled for Tiamzon, citing pest issues, not neglect, and upheld tenant rights.
court of agrarian relations
procedural errors
authority to dispossess
A

Case Summary (G.R. No. 17857)

Factual Background

On 27 July 1956, Pineda filed in the Court of Agrarian Relations, Third Regional District, Tarlac, Tarlac, a complaint against tenant Tiamzon and others praying that they desist from planting their palay in the old system and adopt the “Masagana System,” the approved government method; and, upon refusal, that Pineda be granted authority to dispossess them and to recover damages amounting to 4,000 cavanes of palay plus costs (case No. 182-Tarlac).

On 2 August 1956, Pineda filed another complaint against Tiamzon, praying for authority to dispossess him for failure to “take good care” of his landholding. Pineda alleged that, in addition to his own landholding of about five hectares in barrio San Nicolas, Balas, Concepcion, Tarlac, he also had another landholding of about two and a half hectares in barrio Buenavista, Tarlac, Tarlac, owned by Agapito Ronquillo, which Tiamzon undertook to cultivate without Pineda’s prior knowledge and consent, which Pineda claimed violated section 24, Republic Act No. 1199 (case No. 190-Tarlac).

On 17 November 1956, Pineda filed an amended complaint in case No. 182-Tarlac, alleging further that Tiamzon abandoned his landholding, did not cultivate and weed his field, did not irrigate, and generally neglected his palay because he was holding office daily at the Federation of Free Farmers at Concepcion, Tarlac. Pineda prayed for additional damages, including P500 from Tiamzon and P1,100 and P5.85 as damages from tenants Olimpio David and Emilio Yumol, respectively.

In response, on 29 November 1956, the respondents in case No. 182-Tarlac filed an answer alleging, among other things, that Pineda brought the complaint out of vengeance and spite to harass them, in light of their insistence on their sharing right under law, and they counterclaimed for P3,000 damages. On 4 May 1957, Tiamzon answered the complaint in case No. 190-Tarlac, denying Pineda’s allegations and praying for dismissal and P200 for attorney’s fees.

Pineda filed a second amended complaint on 27 June 1957, increasing the damages as to Tiamzon to P1,000 without otherwise materially affecting the allegations against him. The respondents filed an answer on 13 July 1957.

Development of the Evidence: Ocular Inspection and Reports

On 2 October 1957, Pineda filed an ex parte urgent motion for ocular inspection to verify whether Tiamzon neglected his landholding as claimed. On 3 October 1957, the Court granted the petition and directed Lieutenant Alfredo Pontejos, a JAGO officer assigned to the Court, to conduct an ocular inspection to determine “the extent of farm work so far done and accomplished by the respondent” and to report within five days.

On 5 October 1957, the JAGO officer conducted the ocular inspection with the consent of both parties and with Pineda, together with his son and farm manager Miguel and Ricardo Pineda, at 8:20 A.M. in Tiamzon’s rice farm at San Nicolas, Balas, Concepcion, Tarlac. In the inspection findings, the officer reported that the tenant’s farm had an approximate area of four hectares more or less, located about 500 yards from the barrio proper. The JAGO officer observed that the rice plants were knee-high and that a big portion of the crop had been attacked or was still being attacked by plant pests, with leaves withering. The officer was informed by the parties that stem borers were the pests attacking the standing crop. He also observed that the farm was abundant with weeds, including broad-leaf weeds, and that the pilapiles were not well kept. He further reported that there was no sign that the field had been touched except two rice paddies adjacent to a mud road traversing the hacienda. He noted that the standing crop was planted on 28 August 1957 and that Tiamzon had been contracted by the JAGO officer at the store and office in Concepcion.

On 11 June 1958, Pineda filed his memorandum. On 10 July 1958, the Commissioner submitted a report and recommended that Tiamzon be ordered ejected from his landholding.

Trial Court Decision and Denial of Reconsideration

In its judgment dated 23 July 1958, the Court of Agrarian Relations dismissed Pineda’s petitions for authority to dispossess Tiamzon and ordered Pineda to maintain Tiamzon as tenant. It also denied the respondent tenant’s claim for attorney’s fees.

The Court found that the instructions given by Pineda to follow the Masagana System were “not sufficient.” It attributed the small yield not to the weedy state of the landholding alone, but to the fact that the crop had been attacked with plant pests at a time when the plants were already knee-high and the leaves had withered. The Court reasoned that if the crop had not been so attacked, it would have produced an amount of palay comparable to those tenants shown in the referenced materials as having adopted the Masagana System. It further held that even granting that the landholding was weedy, the small yield was not due to that condition but was due to stem borer attack when the crop was already knee-high. The Court also considered the condition of the palay stacked in the field after harvest, finding it was not wet. It noted that the evidence was not clear that Tiamzon was treasurer of the Free Farmers Association of Concepcion, Tarlac. Even assuming he was, the Court held his efficiency was unimpaired because he had several sub-treasurers assisting in the collection of dues from members.

Pineda filed a motion for reconsideration on 11 August 1958. Tiamzon filed an “opposition to motion for reconsideration” on 8 September 1958. On 18 September 1958, the Court denied Pineda’s motion for reconsideration.

Proceedings in the Supreme Court: Petition for Certiorari and Procedural Objections

On 9 October 1958, Pineda filed with the Supreme Court a petition for a writ of certiorari, alleging that the respondent court acted with grave abuse of discretion and insisting that there was no appeal available. On 31 October 1958, the Supreme Court dismissed the petition for lack of supporting papers. On 4 December 1958, after reconsideration on Pineda’s motion and after he filed the necessary papers, the Supreme Court ordered the respondents to answer.

The respondent court later requested that it be excused from filing an answer, believing its intervention was unnecessary. Tiamzon, on the other hand, answered the petition and raised the procedural objection that the proper mode of review from decisions of the Court of Agrarian Relations was by a petition for review under section 13, Republic Act No. 1267, as amended by Republic Act No. 1409, limited to questions of law. He argued that the petition for certiorari was defective in form and substance because it did not provide reasons for the issuance of the writ, and because it merely stated allegations of fact. He prayed for dismissal with costs against Pineda.

Parties’ Position on the Merits (As Raised in the Petition)

Pineda maintained that Tiamzon stubbornly refused to adopt the Masagana System of planting rice despite Pineda’s orders and the advice of authorities of the Agricultural Tenancy Commission. He claimed that Tiamzon admitted that during the crop year 1956-1957 he did not plant in accordance with the Masagana System, although he allegedly complied in the ensuing crop year. Pineda argued that the agrarian court should have compared yields by considering the average yield between the maximum harvest under the old system and the minimum harvest under the Masagana System. He also relied on the ocular inspection report, asserting that the JAGO officer found Tiamzon’s landholding to be swamped with weeds and that the paddies were not well kept. Pineda further contended that the JAGO officer saw Tiamzon at the Federation of Free Farmers store and office of which he was treasurer when the inspection was conducted, and that these were sufficient grounds for ejectment. Pineda also argued that it had been established that the palay got wet because Tiamzon failed to stack it after harvest in accordance with farm practices. Finally, he asserted that as landlord he had the right to determine whether Tiamzon should adopt the Masagana System, and thus there was no need for a contract.

Pineda framed the issue as grave abuse of discretion, claiming that the agrarian court failed to consider established facts that supported his authority to dispossess Tiamzon. He also argued that the determination by the agrarian court of whether the Masagana System produced greater yields involved facts which, in his view, required correction.

Tiamzon countered that the allegations relied upon in support of

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