G.R. No. L-11951; November 29, 1958
CENON BUENCAMINO, petitioner, vs. HON. PASTOR P. REYES, Judge, Court of Agrarian Relations and FEDERICO PALLASIQUI, respondent.

FACTS

Beginning in 1951, Federico Pallasiqui was the tenant of Cenon Buencamino on a five-hectare land in Lupao, Nueva Ecija, under a written contract requiring Pallasiqui to deliver 110 cavans of palay annually to Buencamino. This relationship ended in April 1956. Pallasiqui filed a case before the Court of Agrarian Relations, alleging he was dispossessed without justifiable cause and demanding reinstatement. He also claimed he had delivered more than the landowner’s lawful share under the Rice Tenancy Law and sought the return of the excess palay. Buencamino defended by asserting that Pallasiqui voluntarily surrendered the land after their five-year contract expired, that Pallasiqui forfeited his tenancy rights by cultivating other landholdings without Buencamino’s consent, that reinstatement was improper as the land was already leased to others not party to the case, and that the 110 cavans received annually was his rightful share. The Agrarian Court rejected the contractual stipulation of 110 cavans as contrary to public policy, applied the 70-30 sharing ratio under Act 4054 and Republic Act 1199, and based on its determination of annual harvests, found Buencamino had received an excess of 134 cavans. It ordered Buencamino to return this excess and reinstate Pallasiqui.

ISSUE

1. Whether the Agrarian Court’s factual finding on the harvest produce and the consequent order for Buencamino to return 134 cavans of palay was supported by evidence.
2. Whether Pallasiqui’s cultivation of another landholding without Buencamino’s knowledge and consent constituted a valid ground for his dispossession and precluded his reinstatement.

RULING

1. On the return of excess palay: The Supreme Court affirmed this part of the Agrarian Court’s decision. It found substantial supporting statements from witnesses for the court’s determination of the harvest produce. The evaluation of the probative value of testimony and resolution of discrepancies were within the lower court’s domain.
2. On reinstatement: The Supreme Court reversed the Agrarian Court’s order for Pallasiqui’s reinstatement. It held that Pallasiqui violated Section 24(1) of Republic Act 1199, which prohibits a tenant from working on two or more separate holdings belonging to different landholders without the knowledge and consent of the landholder with whom he first contracted, whenever his holding is five hectares or more or of sufficient size to fully occupy his household. The Court found clear evidence that Pallasiqui planted corn and vegetables on the land of Attorney Rufino Fernandez during his tenancy with Buencamino, without Buencamino’s knowledge and consent. This violation applied regardless of whether the second holding was planted to rice or another crop like corn. The tenant’s alleged need for rice land to support his family did not excuse the statutory violation. Under Section 50(b) of Republic Act 1199, such a violation is a sufficient cause for dispossession. Coupled with the expiration of the five-year contract, Buencamino was justified in terminating the tenancy. Consequently, the order for reinstatement and any attendant damages were revoked.
DISPOSITIVE PORTION:
The Supreme Court modified the Agrarian Court’s judgment. It affirmed the order directing Buencamino to return the 134 cavans of “Raminad” palay or its equivalent value, with interest. It revoked the directives for Pallasiqui’s reinstatement and for consequent damages.