GR L 19749; (May, 1964) (Digest)
G.R. No. L-19749; May 30, 1964
MONICO CRUZ, petitioner, vs. CAMILO PANGAN and SOTERA (PANGAN) SANTIAGO, respondents.
FACTS
Camilo Pangan was a share tenant on a three-hectare land owned by Leonila Tiongson. In December 1959, Pangan filed a petition before the Court of Agrarian Relations (CAR) to change the sharing arrangement from 50-50 to 70-30 in his favor. Tiongson moved to dismiss, alleging she had sold the land to Monico Cruz in September 1958. Separately, Cruz filed a petition in December 1959 to eject Pangan, asserting his right as the new owner to personally cultivate the land. The two cases were consolidated.
The CAR initially ruled in favor of Cruz, granting him authority to eject Pangan for personal cultivation, subject to conditions under the Agricultural Tenancy Act. However, upon Pangan’s motion for reconsideration, the court reversed itself. It found that the sale to Cruz was orchestrated to circumvent Pangan’s lawful demand for a 70-30 share. The court highlighted circumstantial evidence, including that the sale occurred after Pangan sought the new sharing ratio, the sold parcel was oddly situated in the middle of Tiongson’s larger 22-hectare property, and Cruz was also a tenant of Tiongson.
ISSUE
Whether the sale of the landholding by Tiongson to Cruz was executed in bad faith to effect the ejectment of tenant Camilo Pangan, thereby barring Cruz’s right to dispossess Pangan for personal cultivation.
RULING
The Supreme Court affirmed the CAR’s reconsidered decision, denying Cruz’s petition for ejectment and upholding Pangan’s right to a 70-30 sharing arrangement. The legal logic centers on the principle that the right of a landowner to personally cultivate under Section 22 of Republic Act No. 1199 must be exercised in good faith. The CAR, as the trier of facts, found the sale was a fraudulent subterfuge designed to dispossess Pangan due to his demand for a lawful share. The Supreme Court deferred to this factual finding, noting it was sufficiently justified by the circumstantial evidence, including the suspicious timing and location of the sale. Since the purchase was tainted with bad faith, Cruz’s intention to cultivate could not be considered bona fide. Consequently, the ejectment was improper, and Pangan’s tenancy rights, including the corrected sharing system, were protected. The Court emphasized its limited authority to disturb factual conclusions supported by substantial evidence from the lower court.