G.R. Nos. L-17481 and L-17537-59; April 28, 1962
LIBERATA ANTONIO ESTRADA, CANUTO CENIZAN, NAZARIO DE LA CRUZ, GENARO ALVARO, ET AL., petitioners, vs. COURT OF AGRARIAN RELATIONS and FAUSTINO F. GALVAN, respondents.

FACTS

The petitioners are tenants of respondent Faustino F. Galvan on land in Pangasinan. They filed petitions (CAR Cases Nos. 139-161-TP-’60) seeking a change in the crop-sharing arrangement. They alleged that while a 50-50 sharing ratio for palay was observed, they contributed all items of production, entitling them to a 70-30 division. For tobacco, they claimed the custom was a 2/3-1/3 share in their favor, but the landlord enforced a 50-50 split and paid their share in cash at below-market prices. They also prayed for an 80-20 share for mongo. The landlord countered that the original 1951 contracts stipulated a 50-50 share for all crops, as he supplied farm implements, advanced seedlings, and contributed to expenses for transplanting, fertilizers, and insecticides.
Subsequently, the landlord filed his own petition (CAR Case No. 162-TP-’60) seeking the ejectment of all tenant-petitioners. He alleged they refused to thresh palay using his machine, harvested and absconded with tobacco leaves without reporting, employed sub-tenants without consent, and disobeyed cropping instructions by planting corn instead of palay on upland areas after the tobacco harvest.

ISSUE

The primary issues were: (1) whether the tenants were entitled to a modification of the crop-sharing basis from 50-50 to 70-30 for palay and 2/3-1/3 for tobacco; and (2) whether the landlord had valid grounds to eject the tenants.

RULING

The Supreme Court affirmed the decision of the Court of Agrarian Relations, denying the tenants’ petitions and upholding their ejectment. On the sharing issue, the Court applied Section 41 of the Agricultural Tenancy Act (Republic Act No. 1199), which provides that crop sharing shall be governed by the contract between the parties, and in its absence, by the custom of the place. The evidence established that the original contracts and the continuous practice since 1951 was a 50-50 sharing basis for all crops, including tobacco and mongo. This practice had crystallized into the custom of the place. The landlord’s contributions for seeds, fertilizer, and other expenses, for which he was entitled to reimbursement under the law, justified the 50-50 division. The tenants’ claim for a more favorable share without waiving these landlord contributions was untenable.
Regarding ejectment, the Court sustained the lower court’s findings that the tenants committed serious violations of their tenancy obligations. These included harvesting and curing tobacco without the landlord’s knowledge and without delivering his share, disobeying lawful orders on cropping patterns, and employing sub-tenants without consent. These acts constituted grounds for ejectment under the tenancy laws. The Court noted the tenants’ expressed unwillingness to continue under the 50-50 arrangement, indicating a strained relationship that justified the ejectment order. The decision was thus affirmed in its entirety.