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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Case Background
- Petitioners Lino Sales and Visitacion Salud Sales are appealing a decision from the Court of Agrarian Relations regarding the ejectment of the tenant, Maximo Macatangay.
- The case was docketed as CAR Case No. 103 (Batangas 1957).
- The appeal arises from a claim that the decision to maintain Macatangay on the landholding lacks substantial evidence.
Tenant History
- Maximo Macatangay has been a tenant of the petitioners since 1939.
- In April 1955, Macatangay was removed from his tenancy, and the land was subsequently given to Santiago Villalobos.
- Following his removal, Macatangay filed for reinstatement and damages in the Court of Industrial Relations on April 18, 1955, which became CIR Case No. 5674-R.
Court Proceedings and Judgments
- The case was transferred to the newly established Court of Agrarian Relations following Republic Act 1267.
- The Agrarian Court ruled in favor of Macatangay, ordering his reinstatement as tenant and awarding him P482.10, corresponding to his 60% share of the harvest from April 8, 1955, until reinstatement.
Execution of Judgment
- A writ of execution wa