Title
Sales vs. Santos
Case
G.R. No. L-13065
Decision Date
Dec 29, 1959
A tenant, dismissed in 1955, won reinstatement but was never restored to the land. Landlords claimed abandonment; court ruled no abandonment as tenant was never reinstated post-harvest.

Case Summary (G.R. No. L-13065)

Background of the Case

Maximo Macatangay has been a tenant of Lino and Visitacion Sales since 1939. The conflict began when the petitioners removed him as a tenant in April 1955 and awarded the land to another individual, Santiago Villalobos. Macatangay challenged his removal through legal proceedings, first in the Court of Industrial Relations and subsequently in the newly established Court of Agrarian Relations following the enactment of Republic Act No. 1267, later amended by Republic Act No. 1409.

Court Judgments and Agreements

In the agrarian court, judgment was rendered in favor of Macatangay, ordering his reinstatement as tenant and the payment of damages for his lost harvest share. Despite the court order and a writ of execution issued on November 28, 1956, reinstatement was contingent upon the completion of the ongoing harvest by Villalobos, pending a verbal agreement between the parties.

Dispute Over Reinstatement and Ejectment

After the issuance of the writ, Macatangay agreed to defer taking possession of the land until Villalobos' crops were harvested and did not occupy the land immediately. Subsequently, the petitioners filed a case for Macatangay's ejectment, claiming he had abandoned the land for failing to cultivate it during the agricultural period from January to April 1957.

Finding of the Agrarian Court

The Agrarian Court determined that Macatangay had not actually been reinstated following the harvests in January and March 1957, concluding that he could not be deemed to have abandoned the land, as abandonment requires prior actual possession.

Evidence and A

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