G.R. No. L-17020 November 9, 1964
PABLO ALMARINEZ, petitioner, vs. CRESENCIANA MANABAT POTENCIANO, DIONISIA MANABAT-LOPEZ, FLAVIANA MANABAT and HERMENEGILDO CARIÑO, respondents.

FACTS

Petitioner Pablo Almarinez was the tenant of respondents on their four-hectare riceland in San Antonio, Biñan, Laguna. Respondents filed an ejectment case against him in the Court of Agrarian Relations on February 12, 1958, alleging as a ground that on February 5, 1958, the tenant made excavations using a bulldozer on a considerable portion of the land, causing serious injury to the property. Petitioner, in his answer filed on March 5, 1958, claimed the excavation was done with the landowners’ knowledge and consent and improved the land, and he included a counterclaim for reliquidation of harvests from 1951 to 1957. Concurrently, petitioner was prosecuted and convicted for malicious mischief in the justice of the peace court and the Court of First Instance of Laguna, with an appeal pending in the Court of Appeals during the trial of the ejectment case. Meanwhile, respondent Dionisia Manabat-Lopez became the sole owner of the landholding. On April 30, 1960, the Court of Agrarian Relations rendered judgment authorizing the dispossession of the tenant and ordering the respondents to pay him P347.00. Petitioner appealed this judgment and the denial of his motion for reconsideration.

ISSUE

The primary issue is whether the tenant’s deliberate act of excavating the land, which impaired its productive capacity, constitutes a valid ground for ejectment under the agrarian laws. A secondary issue involves the correctness of the reliquidation award concerning the tenant’s share of the harvests.

RULING

The Supreme Court affirmed the ejectment but modified the reliquidation award. The Court held that the tenant’s deliberate acts of scraping two paddies, leveling or removing the pilapils, and filling up the irrigation canal violated his duties under Section 23, Paragraph 1, and Section 38, Paragraph 3, of Republic Act No. 1199 to take care of the farm as a good father of the family and to maintain dikes, paddies, and irrigation canals. Such violation is a ground for ejectment under Section 50(b) of the same Act, not under Section 50(f) which applies to negligence. The lower court correctly made an independent assessment of the evidence, finding the acts were done without the landowners’ prior knowledge or consent and impaired the land’s productive capacity. Regarding the counterclaim, the Court modified the award, holding that under Section 9 of Republic Act No. 1199 , the transferee of the land (respondents) assumes the obligations of the former landholder to the tenant. Evidence showed for the 1954-55 agricultural year, the net produce was 200 cavans at P9.00 per cavan, and the tenant, having received only 50% instead of his legal 57-½% share, was entitled to an additional 15 cavans valued at P135.00. This amount was added to the P347.00 awarded by the lower court for 1955-1957, resulting in a total award of P482.00. No award was made for harvests before 1954 due to lack of evidence. The judgment was affirmed with the modification increasing the tenant’s award to P482.00, without prejudice to respondents filing an action for reimbursement for the P135.00 corresponding to the 1954-55 share.