G.R. No. L-19760; April 30, 1964
MARCELO VILLAVIZA, ET AL., petitioners, vs. JUDGE TOMAS PANGANIBAN, ET AL., respondents.

FACTS

The petitioners, Marcelo Villaviza and others, were agricultural tenants on a riceland in Aliaga, Nueva Ecija, owned by Domingo Fajardo. Their tenancy commenced in 1944. In the 1955-56 crop year, Fajardo leased the land to Quirino Capalad under a civil lease. Capalad then plowed the land by machinery and installed his own tenants, thereby ousting the original tenants. The ousted tenants demanded reinstatement yearly. Capalad repeatedly promised to reinstate them the following agricultural year but never fulfilled these promises. This led the ousted tenants to file an action for reinstatement and damages before the Court of Agrarian Relations on March 31, 1960.
The agrarian court ruled in favor of the ousted tenants, ordering Capalad to pay them monetary awards and directing his installed tenants to vacate the landholdings in favor of the original tenants. The court, however, limited the damages awarded to the equivalent of two harvests based on the 1954-55 crop year. It cited the ousted tenants’ engagement in other gainful occupations and their delay in filing the suit as reasons for this limitation. The losing parties, including Capalad and his installed tenants, elevated the case to the Supreme Court via petition for review.

ISSUE

The core issue is whether the Court of Agrarian Relations committed grave abuse of discretion or error in its decision, particularly regarding the prescription of the action and the proper computation of damages for illegal ejectment.

RULING

The Supreme Court affirmed the agrarian court’s decision. On the claim of grave abuse of discretion, the Court found it meritless, emphasizing that the Supreme Court’s role in review is not to re-weigh evidence but only to determine if the lower court’s findings are supported by substantial evidence, which they were. On the issue of prescription, the Court held that an action for violation of a tenant’s right to security of tenure under Republic Act No. 1199 prescribes in ten years under Article 1144(2) of the Civil Code. Since the ejectment occurred in June 1955 and the action was filed in March 1960, the ten-year period had not lapsed.
Regarding the computation of damages, the Supreme Court corrected the lower court’s erroneous premises but let the monetary award stand. The Court held that under Section 27(1) of Republic Act No. 1199, as amended, a tenant’s earnings from other occupations cannot be deducted from the damages for illegal ejectment; such earnings are to be in addition to the damages. Furthermore, the ousted tenants were not guilty of laches, as their delay was induced by Capalad’s repeated promises of reinstatement. However, the specific amounts awarded were not increased because the ousted tenants, by not appealing the decision, were deemed to have waived any claim to higher damages and were satisfied with the judgment. Costs were imposed on the petitioners.