G.R. No. L-20672 February 28, 1974
TIMOTEO ANDRES, ET AL., petitioners, vs. ALBERTO DE SANTOS, DE SANTOS AGRICULTURAL DEVELOPMENT CO., INC. and HON. PASTOR P. REYES, Judge, Court of Agrarian Relations, Nueva Ecija, Guimba Branch, respondents.

FACTS

Petitioners, forty-six tenants of respondent De Santos Agricultural Development Co., Inc., filed a complaint in the Court of Agrarian Relations (CAR) seeking to change their crop-sharing arrangement from 55%-45% in favor of the landowner to 70%-30% in their favor for the agricultural year 1961-62. They alleged that their counsel, Atty. Eliseo Tenza, sent letters of notice for this change in March 1961 to the respondent landowner and other pertinent parties, which was at least a month before the commencement of the agricultural year in June 1961, as required by Section 14 of Republic Act No. 1199 (Agricultural Tenancy Act). The respondent landowners refused to comply, leading to the litigation.
The CAR dismissed the complaint, ruling that the petitioners failed to prove that the required notice was timely sent to and received by the landowners. The court found the evidence insufficient, particularly questioning the admissibility and credibility of the presented exhibits, including the carbon copies of the notice letters. The CAR held that without proof of receipt by the landowner, the statutory requirement for effecting a change in the sharing system was not satisfied.

ISSUE

Whether the Court of Agrarian Relations erred in dismissing the petitioners’ complaint for lack of timely notice of the intended change in the crop-sharing arrangement.

RULING

Yes. The Supreme Court reversed the decision of the CAR. While factual findings of agrarian courts are generally respected on appeal, the Court is not bound by them when they are not supported by substantial evidence. In this case, the CAR’s conclusion was contradicted by the evidence on record. Petitioners’ counsel, Atty. Tenza, credibly testified to preparing and sending the notices via registered mail in March 1961. Crucially, the respondent landowner’s own witness, Atty. Jose Dacquel, admitted receiving a copy of the notice sent to him as the landowner’s lawyer. This admission constituted substantial evidence that the landowner, through its counsel, was duly notified within the statutory period.
The legal logic is anchored on the purpose of the notice requirement under the Agricultural Tenancy Act, which is to inform the landowner of the tenant’s desire to change the sharing ratio. Proof of receipt by the landowner’s duly authorized counsel fulfills this purpose. The CAR’s rigid insistence on direct proof of the landowner’s personal receipt, despite evidence of notice to his legal representative, constituted a reversible error. Consequently, the petitioners validly effected the change to a 70%-30% sharing ratio in their favor for the 1961-62 agricultural year and were entitled to the corresponding shares of the harvest previously deposited.