GR 185365; (March, 2016) (Digest)
G.R. No. 185365 . March 02, 2016. RAMON PACON, ET AL., PETITIONERS, VS. BENJAMIN TAN, RESPONDENT.
FACTS
Respondent Benjamin Tan, a co-owner of an agricultural land in Camarines Sur, filed complaints for ejectment against petitioners, who were occupying portions of the property. Tan alleged that petitioners failed to remit the landowner’s share of the harvest and had sold their tenancy rights to third parties. Petitioners countered that they had a tenancy agreement with Tan and had been religiously delivering the 2/3 share of the produce to Tan’s overseer, Sandy Nuñez, through an authorized comprador.
The Provincial Adjudicator dismissed the complaints, finding that Tan’s own affidavit admitting to “irregular and meager remittances” negated a claim of complete non-payment. The Adjudicator ordered petitioners to account for and deliver any arrearages but held that mere failure to pay in full, absent deliberate intent, did not justify ejectment. The Department of Agrarian Reform Adjudication Board (DARAB) affirmed this decision.
ISSUE
Whether the Court of Appeals erred in reversing the DARAB and ordering the ejectment of petitioners based on alleged non-payment of lease rentals.
RULING
The Supreme Court reversed the Court of Appeals and reinstated the DARAB’s decision, holding that ejectment was not warranted. The legal logic is anchored on agrarian law principles which strictly protect tenurial security. Under Section 37 of Republic Act No. 3844 , the burden of proving a lawful cause for ejectment rests solely on the agricultural lessor. The Court found that Tan failed to discharge this heavy burden.
The evidence did not substantiate a deliberate refusal to pay justifying dispossession. Tan’s own affidavit acknowledged receiving some payments, characterizing them as “irregular and meager.” This admission contradicted a claim of absolute non-payment. Furthermore, affidavits from the comprador and barangay official corroborated that payments were made and withheld through Tan’s authorized representative. The alleged sale of rights was also unsupported by evidence. Consequently, the proper remedy was not ejectment but an accounting and payment of any deficiencies, as initially ordered by the Provincial Adjudicator. The Court remanded the case to the DAR for determination of provisional rental, preserving the tenancy relationship while ensuring the landowner receives due compensation.