G.R. No. 176091 ; August 24, 2011
RENE ANTONIO, Petitioner, vs. GREGORIO MANAHAN, Respondent.

FACTS

Petitioner Rene Antonio and respondent Gregorio Manahan entered into a “Kasunduang Buwisan sa Sakahan” (Leasehold Agreement) dated November 16, 1993. Under this agreement, Antonio undertook to cultivate two parcels of agricultural land owned by Manahan for an annual rental of 70 cavans of palay. The agreement stipulated, among other terms, that the land shall be planted exclusively to rice, that Antonio shall not expand his house or allow others to build on the land, that planting and harvest on both parcels shall be simultaneous, and that Manahan shall be given a three-day prior notice of harvests.
In 1994, 1996, and 1997, Manahan filed complaints before the Municipal Agrarian Reform Officer (MARO) against Antonio for violations of the agreement, including non-payment of rentals, planting kangkong (which allegedly impaired land fertility), failure to synchronize planting and harvest, and failure to give prior harvest notice. Due to Antonio’s alleged persistence in these violations, Manahan filed a Complaint for Ejectment (PARAD Case No. IV-Ri-0583-97) on September 16, 1997, before the Provincial Agrarian Reform Adjudicator (PARAD), seeking Antonio’s ejectment and payment of unpaid rentals.
In his Answer, Antonio denied the allegations, claiming he regularly remitted rentals except in 1993 when Manahan refused acceptance, that failure to give notice is not a lawful cause for dispossession under agrarian laws, that the kangkong grew naturally and sporadically without his effort and only on an insignificant portion, and that such planting did not constitute a violation of proven farm practices.
After pre-trial and submission of position papers, the PARAD rendered a Decision on October 4, 1999, in favor of Manahan. It found Antonio violated the Leasehold Agreement by: (a) failing to pay the stipulated rental in full from 1993 to 1998; (b) failing to give prior notification of harvests; and (c) utilizing 3,000 square meters of the land for planting kangkong despite objections. The PARAD ordered Antonio’s ejectment and payment of ₱30,000 as unpaid rental.
On appeal, the Department of Agrarian Reform Adjudication Board (DARAB) initially reversed the PARAD Decision on January 8, 2004, finding that Antonio’s rental shortages did not show a deliberate intent to evade payment and that the kangkong grew naturally. It ordered Manahan to respect Antonio’s possession and dismissed the claim for unpaid rentals.
Manahan filed a Motion for Reconsideration, arguing that failure to pay rentals in full, not being due to fortuitous event, is ground for dispossession under Section 36 of Republic Act No. 3844 , and that Antonio had further violated the agreement by planting other crops (string beans, tomatoes, squash, eggplants) and building a second house and pig pens. The DARAB granted the motion and, after an ocular inspection confirmed some violations, issued a Resolution on December 28, 2004, reinstating the PARAD’s 1999 Decision.
Antonio filed a petition for review with the Court of Appeals (CA-G.R. SP No. 88319). The CA, in its Decision dated October 31, 2006, dismissed the petition, affirming the DARAB Resolution. It held that Antonio’s failure to pay rentals in full over the years and his planting of kangkong were violations of the Leasehold Agreement justifying dispossession under Section 36 of R.A. No. 3844 . Antonio’s motion for reconsideration was denied on January 4, 2007, prompting this petition.

ISSUE

1. Whether the Court of Appeals erred in declaring Antonio guilty of non-payment of lease rentals due to shortages delivered in certain agricultural crop years.
2. Whether the Court of Appeals erred in declaring that Antonio violated the leasehold contract by planting kangkong on a single occasion.
3. Whether the Court of Appeals erred in applying Section 36 (paragraphs 3 and 4) of R.A. No. 3844 as authorized causes for Antonio’s dispossession.

RULING

The Supreme Court found the petition partially meritorious but affirmed the assailed CA Decision.
1. On the issue of non-payment of rentals: The Court agreed with the lower tribunals that Antonio’s failure to pay the stipulated rental in full from 1993 to 1998 constituted a violation of the leasehold agreement and a ground for dispossession under Section 36 of R.A. No. 3844 . The evidence, including Antonio’s own admissions and receipts, showed consistent shortages in the annual deliveries of palay. The law does not require a deliberate intent to evade payment; mere failure to pay or make a tender of payment, if not due to fortuitous event or force majeure, is sufficient cause for ejectment.
2. On the issue of planting kangkong: The Court found that the act of planting kangkong on the landholding, which was stipulated to be planted exclusively to rice, constituted a violation of the terms of the leasehold contract. This violation, under the factual findings of the PARAD and DARAB, impaired the fertility of the land. Such impairment of the land’s productive capacity is a distinct ground for dispossession under Section 36 of R.A. No. 3844 .
3. On the application of Section 36 of R.A. No. 3844 : The Court held that the CA correctly applied Section 36. Antonio’s failure to pay the lease rental when it fell due (paragraph 3) and his violation of the contract through an act impairing the land’s fertility (paragraph 4) are explicit authorized causes for the agricultural lessor to eject the lessee. The burden of proof to show lawful cause for ejectment rests upon the agricultural lessor, and in this case, Manahan sufficiently discharged that burden.
The dispositive portion of the PARAD Decision, as reinstated by the DARAB and affirmed by the CA, was upheld. Antonio was ordered ejected from the landholding and to pay Manahan ₱30,000 for unpaid lease rental.