G.R. No. L-19716 and L-17919, November 23, 1966
Herminigildo Guevara and Apolonio Javinia, petitioners, vs. Hon. Judge Jose M. Santos of the Court of Agrarian Relations and Guillermo Ponce, respondents.

FACTS

In 1958, Guillermo Ponce filed 24 ejectment cases against tenants in the Court of Agrarian Relations. All were dismissed except two: Case No. 207 against Herminigildo Guevara and Case No. 221 against Apolonio Javinia. The lower court ordered them to vacate their landholdings. The court found that Guevara caused the death of 28 coconut trees by heaping and burning hay at their base, and Javinia caused the death of 6 coconut trees by plowing too closely to them, cutting their roots. Both were tenants-lessees of portions of Ponce’s land. They appealed the joint decision.

ISSUE

Whether the tenants-lessees, Herminigildo Guevara and Apolonio Javinia, violated their obligations under the Agricultural Tenancy Act, thereby constituting sufficient cause for their dispossession.

RULING

Yes. The Supreme Court affirmed the lower court’s decision. The tenants-lessees failed to exercise the diligence of a good father of a family to preserve the improvements on their holdings, violating Section 43 of the Agricultural Tenancy Act (R.A. No. 1199). This violation is a statutory ground for dispossession under Section 50(b) of the same Act. The Court rejected the appellants’ argument that the ground for ejectment was Section 50(f) (negligence causing serious injury to the land), noting the lower court did not base its conclusion on that specific section. The Court also rejected the argument that the coconut trees were not part of the tenancy contract, as Section 43 obligates the tenant-lessee to make proper use of the land and improvements and to observe proven farm practices. The appellants admitted they had been taking care of the trees and made no attempt to replace them after destruction, demonstrating indifference contrary to standard farm practices.