G.R. No. L-25846 June 30, 1970
JUANITO MANUBAY, petitioner, vs. FELIX MARTIN and the HON. BIENVENIDO D. CHING CUANGCO, Presiding Judge, Court of Agrarian Relations, Sala I, Fourth Regional District, Cabanatuan City, respondents.

FACTS

Petitioner Juanito Manubay, as plaintiff-lessor, filed an action for ejectment against private respondent Felix Martin, the defendant-lessee, in the Court of Agrarian Relations. The complaint sought Martin’s ejectment from a landholding in Bo. Rajal, Sta. Rosa, Nueva Ecija, devoted to palay production, on the ground that Martin failed to notify Manubay before reaping and pre-threshing a portion of his palay crop in November 1964. Martin moved to dismiss, arguing that under leasehold tenancy, the entire harvest belongs to the lessee and there is no obligation to notify the lessor of reaping or threshing, and that such failure is not a cause for ejectment. The relationship between the parties was that of agricultural leasehold, with Martin having become a leasehold tenant under Republic Act No. 1199 (Agricultural Tenancy Act) effective the 1960-61 agricultural year. It was undisputed that Martin reaped and pre-threshed in November 1964 without informing Manubay, although Manubay later learned of it and sent constabulary soldiers. It was also undisputed that Martin had been paying his lease rental, including for the 1964-65 agricultural year. The parties submitted the case for decision based on these undisputed facts. The respondent court dismissed the ejectment complaint but declared it Martin’s duty henceforth to notify Manubay at least three days before harvesting and threshing, conformably to Republic Act No. 3844 (Agricultural Land Reform Code). Manubay appealed, contending that Martin, having violated Section 26(5) of the Land Reform Code (which requires a three-day advance notice of harvesting/threshing) after its enactment, should be ejected under Section 36(2) of the same Code, and that the Tenancy Act was repealed by the Land Reform Code.

ISSUE

Whether the respondent-lessee, whose leasehold tenancy began under Republic Act No. 1199 (Agricultural Tenancy Act) prior to the effectivity of Republic Act No. 3844 (Agricultural Land Reform Code), can be lawfully ejected for failing to notify the lessor of reaping and threshing in November 1964, based on the provisions of the Land Reform Code.

RULING

No. The Supreme Court affirmed the decision of the Court of Agrarian Relations dismissing the ejectment complaint. The Court held that:
1. The saving clause in Section 4 of the Land Reform Code expressly provides that if a lawful leasehold tenancy contract was entered into prior to the Code’s effectivity, the rights and obligations arising therefrom shall continue until modified by the parties in accordance with the Code. Thus, the Tenancy Act provisions continued to govern the parties’ relations, as Martin’s tenancy began in 1960-61.
2. The respondent court properly sustained Martin’s plea of good faith, as he believed the Tenancy Act governed his obligations, and that Act did not impose a notice requirement on the lessee. The lack of such a requirement in the Tenancy Act was because the lessee’s principal obligation is to pay a fixed rental, a generic thing, and the lessor could verify the date of reaping and threshing.
3. No damage or prejudice was caused to Manubay by the lack of notice, as Martin had been paying his lease rentals, including for the relevant agricultural year, and Manubay claimed no such deprivation in his complaint.
4. The principle of security of tenure requires that for ejectment, the lessee must have substantially failed to comply with contractual or legal obligations. The court has discretion to determine if the cause warrants ejectment. Under the facts, Manubay failed to make a valid case for dispossession.
5. Manubay had no cause for complaint since the respondent court, with Martin’s acquiescence, made the Land Reform Code’s notice requirement prospectively applicable and imposed the duty on Martin to give notice henceforth.
Costs were awarded against petitioner Manubay.