GR L 15192; (October, 1960) (Digest)
G.R. No. L-15192; October 24, 1960
PHILIPPINE NATIONAL BANK, petitioner, vs. TEOFILO RAMIREZ, ET AL., respondents.
FACTS
Since 1953, Agustin Pecio had been cultivating two hectares of land in Balungao, Pangasinan, belonging to the estate of Jose Castillo y Refuerzo. In 1955, the Philippine National Bank (PNB), as administrator of the estate, through its representative Atty. Jose Manalansan, executed tenancy contracts with the hacienda’s tenants. Atty. Manalansan, not knowing the tenants personally, relied on their information. Respondent Teofilo Ramirez approached Atty. Manalansan and falsely represented himself as the tenant of the land, resulting in the execution of a tenancy contract (Exhibit “A”) covering the land actually cultivated by Pecio. Upon learning of the fraud, Pecio reported the matter to Atty. Manalansan. The dispute was referred for conciliation, leading to a “katulagan” or agreement (Exhibit “1”) between Ramirez and Pecio for the agricultural year 1955-1956, whereby they shared cultivation of the land. After that year, Pecio resumed sole cultivation. Ramirez later filed a case in the Court of Agrarian Relations against PNB, alleging illegal ouster and seeking reinstatement and damages. The Agrarian Court, while finding Ramirez guilty of fraud in obtaining the contract, held that the “katulagan” constituted a ratification by Pecio and ordered PNB to reinstate Ramirez to one-half of the land and pay damages. PNB appealed.
ISSUE
Whether respondent Teofilo Ramirez, who obtained a tenancy contract through fraud and misrepresentation concerning land lawfully cultivated by another tenant, is entitled to security of tenure and reinstatement under Republic Act No. 1199.
RULING
No. The Supreme Court reversed the decision of the Court of Agrarian Relations and dismissed the complaint.
The tenancy contract (Exhibit “A”) between PNB and Ramirez is illegal and void. First, it deprived the true tenant, Agustin Pecio, of his security of tenure under Section 7 of Republic Act No. 1199, as he could only be dispossessed for causes enumerated in Section 50 and with court authorization. Second, the contract was obtained through Ramirez’s fraud and misrepresentation, vitiating PNB’s consent and making the contract voidable. Being a nullity, it created no tenancy relationship between PNB and Ramirez and conferred no rights upon him. The “katulagan” or agreement between Ramirez and Pecio, intended only to settle their dispute for the 1955-1956 agricultural year, could not create a landlord-tenant relationship between PNB and Ramirez or entitle Ramirez to the security of tenure under the tenancy law. The law, designed to protect lawful tenants, cannot be invoked to benefit one who became a tenant through deceitful acts.