G.R. No. L-19735 January 23, 1967
TRINIDAD YAPTANGCO VDA. DE TIZON, petitioner, vs. DOMINGO CABAÑGON, as Judge of the Court of Agrarian Relations, Third Regional District, and ROMAULDO DAVID, respondents.

FACTS

Respondent Romualdo David has been a tenant since 1942 on two separate landholdings owned by petitioner Trinidad Yaptangco Vda. de Tizon: one in Barrio San Bartolome, Sto. Tomas, Pampanga (2.0853 hectares), and another in Sto. Tomas, Pampanga (2.3662 hectares). The sharing was 55% for the tenant and 45% for the landholder. On February 8, 1960, David filed a petition with the Court of Agrarian Relations (CAR) seeking a new sharing ratio for the 1959-1960 crop (62.5%-37.5% for San Bartolome and 70%-30% for Sto. Tomas) and a reliquidation of the harvests from 1954-1959 based on new ratios. The CAR issued an interlocutory order for the deposit of portions of the harvest. After trial, the CAR declared the San Bartolome land as second class and the Sto. Tomas land as first class, and ordered new sharing ratios for the 1959-60 crop and a reliquidation for 1956-57 to 1958-59, based on David’s contributions of labor, farm implements, and work animals. The CAR later modified the judgment regarding the Sto. Tomas sharing for the reliquidation years to 57.5%-42.5% as originally prayed by David. The landholder appealed.

ISSUE

The primary issue is whether, for purposes of classifying ricelands under the Agricultural Tenancy Act and determining the legal share of the produce, separate landholdings cultivated by one tenant should be considered individually or aggregated as one unit.

RULING

The Supreme Court affirmed the CAR decision. It ruled that for purposes of classification under Sections 32 and 33 of the Agricultural Tenancy Act, the production of each separate landholding should be taken into account individually, not aggregated. The San Bartolome land, with a normal average yield of about 37 cavans per hectare (not more than 40), was correctly classified as second class land. The Sto. Tomas land, with a normal average yield of about 54 cavans per hectare (more than 40), was correctly classified as first class land. The Court held that the law refers to “ricelands,” implying that a tenant may have separate landholdings under different classifications, and doubts in interpretation should be resolved in favor of the tenant under Section 56 of the Act. The Court also upheld the change in sharing for the 1959-60 crop, finding the demand was made before the completion of transplanting, and affirmed the reliquidation for the 1956-57 to 1958-59 crops, rejecting the landholder’s defense that the action should have been against her former farm manager. Costs were imposed on the petitioner.