G.R. No. L-18412; July 31, 1962
JOSE SANTOS, petitioner, vs. CECILIA LOPEZ VDA. DE CERDENOLA, and HON. JUDGE PASTOR DE GUZMAN, of the Court of Agrarian Relations, First Regional District, Lingayen, Pangasinan, respondents.

FACTS

Respondent Cecilia Lopez Vda. de Cerdenola filed a petition for reinstatement in the Court of Agrarian Relations against petitioner Jose Santos, the administrator of Hacienda Esperanza, and a new tenant, Juan Blanco. She alleged that she and her late husband had been tenants on a portion of the hacienda for over thirty years. After her husband’s death in November 1952, she continued cultivating the landholding, delivering the landholder’s share to the overseer and receiving annual assistance from the hacienda until her alleged unlawful ejectment in 1958, when her place was given to Blanco. She sought reinstatement and damages. In their separate answers, both Santos and Blanco denied the material allegations, contending that the tenancy relationship terminated upon the death of Cerdenola’s husband.
During the proceedings, after Cerdenola presented part of her evidence, Blanco moved to dismiss for insufficiency of evidence. The court denied the motion and considered the case submitted for decision based on the evidence on record. Santos’s counsel filed a motion for reconsideration, which was also denied. The court subsequently rendered a partial decision on October 25, 1960, declaring Cerdenola entitled to reinstatement, with damages to be determined later. A final order fixing damages was issued on March 21, 1961.

ISSUE

The primary issue is whether the Court of Agrarian Relations acted without jurisdiction or with grave abuse of discretion in issuing its partial decision and final order, thereby allegedly depriving petitioner Santos of his day in court.

RULING

The Supreme Court dismissed the petition for certiorari. On procedural grounds, the Court found that the proper remedy was an appeal, not certiorari. The partial decision of October 25, 1960, became final and executory as Santos took no steps to appeal it. The subsequent final order of March 21, 1961, was also not appealed within the reglementary period. Certiorari cannot substitute for a lost appeal, especially when the finality of the judgment resulted from the petitioner’s own inaction.
On the substantive merits, the Supreme Court upheld the agrarian court’s decision. The legal logic centered on the establishment of an implied tenancy relationship under Republic Act No. 1199, as amended. While the death of the original tenant (Cerdenola’s husband) could have extinguished the relationship under the old law, the conduct of the parties after his death created a new tenancy contract by implication. From 1952 to 1958, Cerdenola, assisted by members of her immediate farm household, continued to cultivate the land, delivered the landholder’s share, and received yearly assistance from the hacienda’s overseer. This constituted an implied contract of tenancy under Section 7 of Republic Act No. 1199. Consequently, Cerdenola acquired security of tenure, making her ejectment in 1958 unlawful. The Court found no grave abuse of discretion in the lower court’s factual findings and application of the agrarian law.