G.R. No. L-18610; April 22, 1963
ANGEL BERMUDEZ, ET AL., petitioners, vs. MARGARITA FERNANDO, respondent.

FACTS

Petitioners Angel Bermudez and Isabelo Sampaga were share tenants on the landholdings of respondent Margarita Fernando in Nueva Ecija. For the agricultural year 1958-1959, their contracts stipulated a 50-50 sharing system, with the transplanting expenses to be shouldered by the landowner. These contracts were not renewed for the 1960-1961 season. In August 1960, the petitioners refused to accept the sums of P45.00 and P60.00, respectively, which the respondent tendered to cover the transplanting expenses for that new agricultural year.
Consequently, the respondent consigned these amounts with the Court of Agrarian Relations (CAR) and sought a judicial order compelling the petitioners to accept them as fulfillment of her obligation. In their answer, the petitioners alleged two key points: first, that they had notified the respondent in January 1960 of their desire to convert their tenancy from sharehold to leasehold under Republic Act No. 1199; and second, that they had already personally defrayed the transplanting expenses by the time the tender was made in August.

ISSUE

The primary issues were whether the petitioners effectively notified the respondent of their intent to convert to leasehold tenancy and whether the respondent’s tender of transplanting expenses was timely made before the petitioners incurred such costs themselves.

RULING

The Supreme Court affirmed the decision of the Court of Agrarian Relations. On the first issue, the Court upheld the CAR’s factual finding that there was insufficient evidence to prove the petitioners notified the respondent of their desire to shift to leasehold tenancy. The record showed the petitioners did not even testify to this effect during the trial. On the second issue, the Court also sustained the CAR’s finding that the respondent’s tender of the transplanting expenses in August 1960 was made “before the commencement of the transplanting season” in the locality, and therefore was timely. The petitioners’ claim of having already spent their own funds was not substantiated.
The legal logic applied is the well-settled doctrine that the factual findings of the Court of Agrarian Relations are conclusive and binding on the Supreme Court, provided they are supported by substantial evidence. The Court emphasized its limited role as a reviewer of questions of law, not a trier of facts. Since the CAR’s findings—that no conversion notice was given and the tender was seasonably made—were substantiated by the evidence on record, there was no legal basis to overturn them. The consignation was thus valid, discharging the respondent’s obligation for the transplanting expenses for the 1960-1961 agricultural year.