G.R. No. L-19740 December 17, 1966
SEVERINO GAGOLA, petitioner, vs. COURT OF AGRARIAN RELATIONS, EMILIANA ALCALA-ALCALA and WENCESLAO DE CASTRO, respondents.

FACTS

Petitioner Severino Gagola filed a petition for reinstatement and damages against respondent Emiliana Alcala-Alcala before the Court of Agrarian Relations (CAR). Alcala is the owner of a parcel of land planted with coconut and buri trees in Sariaya, Quezon. Gagola claimed he was a tenant on the land from 1945 until he was unlawfully ejected in January 1955. Alcala countered that Gagola was merely a hired laborer who worked intermittently and was dismissed in 1952 due to negligence and slothfulness. The CAR, after evaluating the evidence, found that Gagola was indeed a tenant on a share basis. However, it concluded that Gagola was not ejected but had voluntarily abandoned the landholding. Consequently, the CAR dismissed Gagola’s petition.

ISSUE

The sole issue raised by Gagola on appeal is one of law: whether the CAR erred in ruling that Gagola had the burden to prove unlawful ejectment and that Alcala was not required to show a lawful cause for dismissal, given Alcala’s admission in her reply that she dismissed Gagola.

RULING

The Supreme Court affirmed the decision of the Court of Agrarian Relations. The Court held that the purely legal issue raised by Gagola regarding the burden of proof need not be addressed because the CAR’s factual finding of voluntary abandonment, which Gagola did not challenge, was dispositive. The Court reviewed the record and agreed that the finding of abandonment was supported by substantial evidence. Under Section 9 of Republic Act 1199, tenancy relationship is extinguished by the abandonment of the land by the tenant. Since Gagola voluntarily left the landholding, the tenancy relationship was terminated by his own act. Consequently, he no longer had standing to invoke the principle of security of tenure. The petition was dismissed.