G.R. No. L-13858; May 31, 1960
CANUTO PAGDAÑGANAN, petitioner, vs. COURT OF AGRARIAN RELATIONS, ET AL., respondents.

FACTS

Petitioner landholder Canuto Pagdañganan filed a petition with the Court of Agrarian Relations (CAR) seeking the ejectment of 15 of his tenants on grounds of alleged violations of the Tenancy Law ( Republic Act No. 1199 ). The specific charges were: (1) during the 1955-56 agricultural year, the tenants reaped their palay crops without the landholder’s knowledge and permission; (2) they stacked their harvest in a place other than the one designated by the landholder; (3) they appropriated loose grains for their own use without informing the landholder; and (4) some tenants refused to sign tenancy contracts prepared by him. The tenants denied the allegations and counterclaimed for damages. After trial, the CAR dismissed both the petition for ejectment and the counterclaim. The landholder’s motion for reconsideration was denied, prompting this petition for review.

ISSUE

Whether the acts committed by the respondent tenants constitute sufficient grounds for their ejectment under Republic Act No. 1199 (The Agricultural Tenancy Act).

RULING

The Supreme Court AFFIRMED the decision of the Court of Agrarian Relations, holding that none of the alleged acts warranted the ejectment of the tenants.
1. On reaping without permission: The Court found no violation. Section 36 of Republic Act No. 1199 grants the tenant the right to determine when to reap, provided it is in accordance with proven farm practices and after due notice to the landholder. The evidence only showed a lack of permission, not a lack of notice. The Court also clarified that Section 39, which prohibits reaping a portion of the crop before the set threshing date without mutual consent, was inapplicable as it pertains to partial reaping, not the reaping of the entire harvest.
2. On stacking harvest in a non-designated place: The Court upheld the CAR’s finding that this was not a sufficient ground for dispossession. While Section 37 grants the landholder the right to determine the stacking site, it is subject to the proviso that the site must not be farther than one kilometer from the center of the cultivated area and, in case of disagreement, the court shall determine a site in the interest of both parties. The tenants had objected to the landholder’s chosen site due to practical difficulties (a muddy pathway posing risks of loss or damage). The landholder failed to demonstrate any prejudice from the tenants’ action. The Court emphasized that the Tenancy Law is remedial, and doubts in its enforcement must be resolved in favor of the tenant.
3. On the stipulation in signed contracts: For those tenants who had signed contracts granting the landholder the right to choose the stacking site, the Court ruled that such stipulation must be read in conjunction with the limitations imposed by the Tenancy Law, which is deemed part of the contract. To rule otherwise would allow landholders to circumvent the law and create ejectment causes at will.
4. On appropriating loose grains: The Court accepted the CAR’s factual findings, which were not disputed. The tenants brought the loose grains (fallen palay stalks) home only after the barrio lieutenant had determined and noted the quantity, and because the landholder’s overseer refused to liquidate them, leaving them at risk of loss in the field. The landholder suffered no damage. The Court found this act justified and not a ground for ejectment. It also clarified that this did not constitute “pre-threshing” under Section 39, as no threshing was involved.
5. On refusal to sign tenancy contracts: The Court held that a tenant’s refusal to sign a written contract is not among the exclusive grounds for dispossession enumerated in Section 50 of Republic Act No. 1199 . The refusal in this case was linked to a disagreement over the crop-sharing basis.
Costs were imposed against the petitioner landholder.