GR 145568; (November, 2005) (Digest)
G.R. No. 145568 November 17, 2005
HEIRS OF ENRIQUE TAN, SR., represented by ROMMEL TAN, Petitioners, vs. REYNALDA POLLESCAS, Respondent.
FACTS
Petitioners are co-owners of a coconut farmland. The original tenant, Esteban Pollescas, was succeeded by his son Enrique upon his death in 1991, with the appointment by landowner Enrique Tan. Respondent Reynalda, Esteban’s surviving spouse, demanded recognition as the rightful successor. The DARAB-Ozamis declared Reynalda the lawful tenant and ordered harvest sharing on a 2/3 to 1/3 (landowner/tenant) basis. Reynalda subsequently failed to deliver the landowners’ 2/3 share for several harvests in 1993, amounting to P3,656.70.
The Tan Heirs filed an estafa case, resulting in Reynalda’s criminal conviction. They then initiated an ejectment case before the DARAB-Misamis Occidental, which ruled in their favor and ordered Reynalda’s ejectment. On appeal, the DARAB Central Office reversed this decision, ordering the Tan Heirs to respect Reynalda’s possession. The Court of Appeals affirmed the DARAB’s reversal, prompting this petition.
ISSUE
Whether Reynalda’s failure to deliver the landowners’ share of the harvest constitutes a valid ground for ejectment under agrarian laws.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic centers on the interpretation of grounds for ejectment under the Agricultural Leasehold System ( Republic Act No. 3844 , as amended). The Court held that mere failure to pay or deliver the landowner’s share does not automatically justify ejectment. For such failure to be a ground, it must be deliberate and willful. The Court found no such deliberate intent, as Reynalda acted under a bona fide belief regarding her right to a share for the 1992-1993 harvests pending litigation and attempted a set-off.
Crucially, the Court ruled that the stipulated 2/3 share for the landowner was illegal. Under Section 34 of R.A. 3844, lease rental for lands devoted to crops other than rice cannot exceed 25% of the average normal harvest. Therefore, the obligation Reynalda failed to meet was not a “legal rental.” Ejectment for non-payment requires failure to pay a legal rental. Since the demanded 2/3 share was excessive and void, her failure to pay it could not be a valid ground for ejectment. The agricultural leasehold relation, once established, is protected, and its extinguishment is strictly limited to the specific grounds enumerated in the law, which were not sufficiently proven in this case.