G.R. No. L-21697 September 23, 1966
FRED ENRIQUEZ, petitioner, vs. HON. DOMINGO M. CABANGON, Presiding Judge, CAR, San Fernando, Pampanga, and JUAN MANALO, respondents.

FACTS

The case originated from a petition filed by tenant Juan Manalo against his landlord, Fred Enriquez, in the Court of Agrarian Relations (CAR). Manalo sought to recover 10-1/3 cavans of palay deducted from the gross produce, which corresponded to reaping and insecticide expenses he incurred but which the landlord took. He also petitioned to change the tenancy system from share tenancy to leasehold under Republic Act No. 1199 , with an annual rental of 37.5 cavans. Enriquez admitted taking the palay but contested the change of tenancy system, arguing its unconstitutionality and non-applicability due to lack of proper notice. He also counterclaimed for ejectment, alleging the tenant cultivated other lands without consent, injured the landholding, and that the land was needed for cultivation by his son. The CAR ruled in favor of Manalo, ordering the return of the palay, authorizing the change to leasehold tenancy effective the 1963-1964 agricultural year, and dismissing the landlord’s counterclaims. Enriquez appealed directly to the Supreme Court.

ISSUE

1. Whether the tenant is entitled to recover the 10-1/3 cavans of palay corresponding to reaping and insecticide expenses.
2. Whether the provision of Republic Act No. 1199 allowing a change in the tenancy system is constitutional.
3. Whether the tenant’s petition itself constitutes sufficient notice to effect the change in tenancy system under Section 14 of Republic Act No. 1199 .
4. Whether the tenant forfeited his right to change the system by allegedly cultivating other properties in excess of the area allowed and employing subtenants.
5. Whether the landlord’s counterclaim constitutes sufficient notice of his intention to have the land cultivated by his son under Section 50(a) of the Agricultural Tenancy Act.

RULING

1. Yes. The Supreme Court affirmed the CAR’s decision ordering the return of the 10-1/3 cavans of palay. The Court held that Section 34 of Republic Act No. 1199 , which bars reimbursement for contributions to production, does not apply to expenses for seed, fertilizer, pest control, reaping, and threshing. Under Section 32, such expenses are deducted from the gross produce and are reimbursable to the party who incurred them. Since the palay taken by the landlord covered reaping and insecticide expenses shouldered by the tenant, the tenant has a clear right to recover them.
2. Yes. The Supreme Court upheld the constitutionality of Section 14 of Republic Act No. 1199 , citing its previous final decisions in Ramas vs. C.A.R. and Vda. de Macasaet vs. C.A.R., which had already affirmed its validity. No new arguments were presented to warrant a deviation from these rulings.
3. Yes. The Supreme Court ruled that the tenant’s petition itself, served on the landlord, constitutes sufficient notice to effect the change in the tenancy system. Section 14 of Republic Act No. 1199 , as amended, only requires that the right be exercised “at least one month before the agricultural year when the change shall be effected” and does not prescribe any particular form of notice. Since the CAR made the change effective for the agricultural year 1963-1964, following the 1962 petition, no prejudice was caused to the landlord.
4. No. The Supreme Court found no factual basis for the landlord’s claim that the tenant forfeited his rights by cultivating other properties in excess of the area allowed or by employing subtenants, as the Agrarian Court had found these allegations to be non-existent. Questions of fact are beyond the scope of the Supreme Court’s review in this direct appeal, as the appellant had effectively waived them by not appealing to the Court of Appeals on questions of fact as required by law.
5. No. The Supreme Court held that the landlord’s counterclaim does not constitute sufficient notice of his intention to have the land cultivated by his son. Section 50(a) of the Agricultural Tenancy Act explicitly requires the landholder to file notice with the Court and inform the tenant in writing at least one year prior to the petition for dispossession. This written notice is a separate requirement that cannot be merged with the petition or counterclaim itself.
The decision of the Court of Agrarian Relations was affirmed in its entirety, with costs against petitioner Fred Enriquez.