G.R. No. L-13431; November 24, 1959
VICENTE CAHILO, petitioner, vs. JUDGE PASTOR DE GUZMAN and LA FUENTE, respondents.

FACTS

Simeon La Fuente filed a petition before the Court of Agrarian Relations seeking reinstatement as tenant and liquidation of the sugar crop share for the agricultural year 1956-1957 from a portion of a lot in Himamaylan, Negros Occidental. The action was against Vicente Cahilo, the receiver appointed by the Court of First Instance of Negros Occidental in Civil Case No. 2435. Cahilo defended that La Fuente had no right to be a tenant because he was placed there by Francisco Sanicas, whose ownership of the land was disputed in the pending civil case; that La Fuente was estopped due to his failure to assert his tenancy rights during the trial of that case; and that the entire sugar crop had been mortgaged by Sanicas to the Philippine National Bank.
The agrarian court, presided by Judge Pastor de Guzman, ruled in favor of La Fuente, declaring him the tenant from 1953 to 1957, ordering Cahilo to pay La Fuente P421.65 as his sugar share for 1956-1957, and to deliver 667.8 kilos of molasses or its monetary equivalent. Cahilo appealed this decision.
The background reveals that Lot No. 1687-B was originally owned by Juan Labansawa. After his death, his heirs possessed it until 1952, when Isabel Senoro et al. fraudulently obtained a title and sold the land to Socorro Suldivilla (wife of Francisco Sanicas). The Labansawa heirs then filed Civil Case No. 2435 for recovery of the property. Cahilo was appointed receiver, took possession, and ejected La Fuente from the land, leading to the present agrarian case.

ISSUE

1. Whether the Court of Agrarian Relations erred in finding Simeon La Fuente to be a tenant from 1953 to 1957.
2. Whether La Fuente is estopped from filing the petition due to his non-intervention in Civil Case No. 2435.
3. Whether the agrarian court correctly computed La Fuente’s 70% share of the 1956-1957 sugar crop.
4. Whether the agrarian court had jurisdiction over receiver Vicente Cahilo.

RULING

The Supreme Court affirmed the decision of the Court of Agrarian Relations.
1. On the Tenancy Relationship: The Court upheld the agrarian court’s factual finding, based on substantial evidence, that a tenancy relationship existed between La Fuente and Francisco Sanicas from 1953 to 1957. Cahilo’s negative testimony could not overcome La Fuente’s positive evidence and documentary proof (Exhibit “D”). The Supreme Court declined to review this factual determination.
2. On Estoppel: La Fuente’s failure to intervene in Civil Case No. 2435 did not estop him from filing the agrarian case. His claims for reinstatement and crop liquidation fall under the exclusive jurisdiction of the Court of Agrarian Relations as provided in Section 21 of Republic Act 1199. He reasonably expected the Sanicas spouses to protect his interest in the civil case.
3. On the Crop Share Computation: The Court sustained the agrarian court’s finding that La Fuente was entitled to a 70% share under his oral tenancy contract with Sanicas, as La Fuente provided all production and cultivation expenses. The liquidation, based on the sale of 44.62 piculs of sugar at P13.50 and the unaccounted 954 kilos of molasses, resulting in P421.65 and 667.8 kilos of molasses respectively, was a factual finding supported by substantial evidence and not subject to review.
4. On Jurisdiction over the Receiver: The Court held that the agrarian court had jurisdiction over Cahilo. Under Section 7, Rule 61 of the Rules of Court, a receiver has the power to bring and defend actions in his own name, subject to the appointing court’s control. The action was properly instituted against Cahilo as receiver, especially since the ejectment of La Fuente was effected by Cahilo in his capacity as receiver.
The decision was affirmed, with costs against petitioner Vicente Cahilo.