GR L 11068; (April, 1958) (Digest)
G.R. No. L-11068; April 30, 1958
J. MARIANO DE SANTOS, petitioner, vs. CATALINO CONCEPCION and HONORABLE GUILLERMO S. SANTOS, as Executive Judge of the Court of Agrarian Relations, respondents.
FACTS
Petitioner J. Mariano de Santos, owner of a hacienda in Cuyapo, Nueva Ecija, filed a petition in May 1954 with the Court of Industrial Relations (later transferred to the Court of Agrarian Relations) to eject his tenant, Catalino Concepcion, from a three-hectare parcel. The grounds alleged were Concepcion’s lack of work animals causing late planting, laziness, disobedience regarding cleaning dikes and canals and removing weeds, resulting in a harvest of only 80 cavans of palay instead of the regular 180 cavans. Despite service of summons, Concepcion failed to file an answer or appear at hearings, leading to his being declared in default. Petitioner presented evidence solely through the testimony of his overseer, Melecio Rivera, who corroborated the allegations of neglect and disobedience leading to the poor harvest. Respondent Judge Guillermo S. Santos, after reading the transcript, denied the ejectment petition, finding the overseer’s uncorroborated testimony insufficient to establish willful disobedience or neglect, citing the burden of proof on the landlord and the policy of security of tenure.
ISSUE
Whether the Court of Agrarian Relations erred in denying the petition for ejectment based solely on the uncorroborated testimony of the landlord’s overseer, who was an interested witness, despite the tenant being in default.
RULING
The Supreme Court set aside the decision and remanded the case to the Court of Agrarian Relations for further proceedings. The Court held that the testimony of a lone witness, if credible, is sufficient to prove a claim, and the fact that the witness is an employee or overseer does not automatically discredit his testimony. Respondent Judge could not assess the witness’s credibility from the transcript alone, as he did not observe the witness’s demeanor. However, in the interest of justice and considering the four-year lapse since the petition’s filing, the tenant should be given an opportunity to present his defense, and the landlord should be allowed to present additional corroborative evidence if desired. The remand would allow for a determination of whether the tenant had mended his ways or continued his neglect, or whether he could prove he was a good tenant, thereby establishing his right to security of tenure. No costs were awarded.