G.R. No. L-23564 November 28, 1969
CANUTO PAGDANGANAN, petitioner, vs. ELADIO GALLETA (alias ALBERTO GALLETA) and DOMINGO GALLETA, respondents.

FACTS

Petitioner Canuto Pagdanganan was the civil law lessee of a land owned by Hacienda Favis. Felix Galleta, father of respondents, was the tenant on this landholding. Upon Felix Galleta’s death on November 20, 1962, Pagdanganan notified Galleta’s widow that he and his sons would personally cultivate the land starting the 1963-1964 agricultural year. Respondents Eladio and Domingo Galleta filed a petition with the Court of Agrarian Relations to be declared the lawful tenant by succession. Pagdanganan planted palay in April 1963, but no harvest was realized due to drought. Pagdanganan’s defense was the termination of the tenancy relationship upon the tenant’s death and his right to personally cultivate the land. The agrarian court ruled in favor of the respondents, ordering Pagdanganan to choose between the two heirs to succeed their father and to reinstate the chosen successor, and awarded damages to the respondents. Pagdanganan appealed.

ISSUE

May the heirs of a deceased tenant be dispossessed by the landholder, who is a civil law lessee of the owner, upon the ground that said landholder-lessee wants to personally cultivate the land himself?

RULING

No. The Supreme Court affirmed the agrarian court’s decision, with modification regarding damages. The Court held that under Section 9 of Republic Act 1199 (Agricultural Tenancy Act), as amended by Republic Act 2263, the tenancy relationship continues between the landholder and a qualified heir upon the tenant’s death. The right to dispossess a tenant’s successor on the ground of personal cultivation is governed by Section 50 of the same Act, as amended, which limits this right solely to the “landholder-owner or his relative within the first degree by consanguinity.” Since Pagdanganan was merely a lessee and not the landowner, he could not invoke this ground for dispossession. Interpreting “landholder” in Section 9 to mean “landholder-owner” harmonizes the provisions and prevents fraudulent schemes to defeat the tenant’s security of tenure, which the law intended to fortify. Regarding damages, the Court ruled that no damages should be awarded for the 1963-1964 agricultural year because the lack of harvest was due to a fortuitous event (drought), and the statutory measure of damages is the landholder’s share of the harvest, which was nil. However, damages for succeeding years until actual reinstatement were upheld.