GR 120363; (October, 1997) (Digest)
G.R. No. 120363 September 5, 1997
CECILLEVILLE REALTY and SERVICE CORPORATION, petitioner, vs. THE COURT OF APPEALS and HERMINIGILDO PASCUAL, respondents.
FACTS
Petitioner Cecilleville Realty and Service Corporation owns a parcel of land in Bulacan. Private respondent Herminigildo Pascual occupies a portion of this land, claiming he is helping his mother, Ana Pascual, petitioner’s tenant, cultivate it. After repeated demands to vacate were refused, petitioner filed an ejectment suit against private respondent before the Municipal Trial Court (MTC). The MTC found no tenancy relationship between petitioner and private respondent and ordered private respondent to vacate, pay attorney’s fees, and monthly compensation. On appeal, the Regional Trial Court (RTC) set aside the MTC decision and remanded the case to the Department of Agrarian Reform Adjudication Board (DARAB), holding that ejecting the son would deprive the tenant of assistance from her immediate farm household. The Court of Appeals affirmed the RTC, finding a tenancy relationship existed and that private respondent, as a member of the tenant’s immediate farm household, was entitled to security of tenure and could maintain his own house on the property. Petitioner filed this petition, conceding that Ana Pascual is a bona-fide tenant and that she may be assisted by a household member, but contesting the grant to private respondent of a right to a home lot and to maintain his own separate house on the land.
ISSUE
Whether a member of a tenant’s immediate farm household, who is not the tenant himself, is entitled under Republic Act No. 1199 , as amended, to a home lot and the right to construct or maintain his own separate house on the landholding.
RULING
No. The Supreme Court granted the petition, reversed the inconsistent part of the Court of Appeals’ decision, and reinstated the MTC decision ordering private respondent to vacate and pay sums as awarded. The Court held that Section 22(3) of Republic Act No. 1199 , as amended, unambiguously grants the right to demand a home lot and to construct a dwelling only to the tenant. Private respondent, who admitted he was not the tenant but merely a member of the tenant’s immediate farm household, is not entitled to such a right. Allowing all household members to have separate home lots would undermine the agricultural purpose of the landholding, lessen productivity, and contravene the law’s aim of ensuring equitable division of produce and efficient agricultural production. The Court further noted that the tenant, Ana Pascual, already had an existing home lot and house where private respondent could stay, and that the law aims to protect both tenants and landholders. The policy of social justice does not justify granting an undeserved privilege.