G.R. No. L-18240; January 31, 1963
SOFRONIO C. QUIMSON, ET AL., petitioners, vs. THE HON. PASTOR L. DE GUZMAN, Presiding Judge of the Court of Agrarian Relations, First Regional District, Lingayen, Pangasinan and ISIDRO TUGADE, respondents.

FACTS

Petitioners, the landlords, filed a complaint in the Court of Agrarian Relations seeking to eject their tenant, respondent Isidro Tugade, from a 26,640-square-meter riceland in Pangasinan. The grounds for ejectment included Tugade’s alleged failure to pay the full agreed annual rental of 1,495 kilograms of palay, voluntary surrender of the landholding, the landlords’ intention to personally cultivate or use machinery, the tenant’s acceptance of another landholding without consent, and his failure to adopt the “Masagana” system of cultivation. The agrarian court dismissed the complaint, finding the land to be second class and the tenancy relationship governed by the leasehold system. While acknowledging Tugade had never paid the full agreed rental, the trial court denied the claim for unpaid rentals, stating it had no concrete basis to fix the correct amount, and held that the tenant had substantially complied with his obligations.

ISSUE

The core issue is whether the agrarian court correctly dismissed the complaint for ejectment and the claim for unpaid rentals.

RULING

The Supreme Court affirmed the dismissal. The legal logic centers on the mandatory limits for leasehold rentals under Republic Act No. 1199 (Agricultural Tenancy Act). The land was judicially determined to be second class, meaning its normal average yield is 40 cavans or less per hectare. Applying the legal formula, the maximum allowable rental was 25% of the gross produce. For a 2.664-hectare land with a maximum yield of 40 cavans per hectare, the gross produce is 106.56 cavans. Twenty-five percent of this yields a maximum legal rental of 26.64 cavans. Converting the claimed rental of 1,495 kilograms using the official cavan weight of 44 kilograms results in nearly 34 cavans, which unlawfully exceeds the statutory maximum. Consequently, the stipulated rental was unenforceable for being in excess of the legal limit, and the tenant’s failure to pay this excessive amount could not constitute a valid ground for ejectment.
Regarding the other grounds for ejectment, the Court found them unmeritorious. On voluntary surrender, even if it occurred, the tenancy relationship was deemed re-established when landlords allowed the tenant to resume working the land. The notice of intention to personally cultivate was invalid due to the landlords’ failure to present the required certifications from government agencies. The claim that the tenant cultivated another landholding failed due to lack of proof it was acquired after the effectivity of RA 1199 and that it caused neglect of the petitioners’ land. The failure to adopt the “Masagana” system was insignificant absent proof the land was suited for it. A belated constitutional challenge to the security of tenure provisions was not considered, as it was not raised in the proceedings below.