G.R. No. L-28090 September 4, 1975
CLEMENTE DEQUITO, petitioner-appellant, vs. VICTORIA LLAMAS, respondent-appellee.

FACTS

Petitioner Clemente Dequito, an agricultural share tenant, filed a complaint for “Reliquidation and Damages” against landowner Victoria Llamas in the Court of Agrarian Relations. He alleged an illegal 50-50 sharing arrangement from 1959-1967, dispossession from a portion of the landholding, unpaid shares from bamboo sales, and usurious loans. He sought monetary claims for alleged short shares, unrealized plantings, and damages.
The respondent landowner moved to dismiss the complaint, presenting a sworn affidavit executed by Dequito dated June 1, 1967. In this affidavit, Dequito stated under oath that the liquidation and sharing with Llamas were in accordance with law, that he had no more claims against her, and that he voluntarily surrendered his landholding after receiving P700.00 as full payment for all improvements he introduced. The agrarian court granted the motion and dismissed the complaint, finding the affidavit a valid basis for the termination of the tenancy relationship.

ISSUE

Whether the Court of Agrarian Relations committed grave abuse of discretion in dismissing the complaint based on the tenant’s sworn affidavit of voluntary surrender and acknowledgment of full settlement.

RULING

The Supreme Court affirmed the dismissal. The legal logic centers on the validity and binding effect of the tenant’s sworn affidavit. The Court scrutinized the document and found it to be a clear, voluntary, and unequivocal act. Dequito, under oath and without coercion, acknowledged the lawfulness of past sharing, declared he had no further claims, and confirmed the surrender of his landholding for a monetary consideration. This constituted a valid voluntary surrender under Section 9 of Republic Act No. 1199 , a lawful ground for terminating the tenancy relationship.
The Court rejected the petitioner’s argument that the affidavit involved a waiver of rights contrary to public policy under Article 6 of the Civil Code. It distinguished the case from those where tenants are tricked into surrendering their rights. Here, Dequito failed to plead or prove any vitiating circumstance like fraud, mistake, or intimidation that would invalidate his sworn statements. The affidavit was treated not merely as a waiver but as a judicial admission and a solemn act of surrender. The principle of social justice cannot be used to invalidate a tenant’s own deliberate and sworn acts, especially when he seeks to repudiate them without justification. Consequently, the agrarian court correctly relied on the affidavit as a conclusive bar to the action for reliquidation. The claims for usurious loans were properly deemed subject to a separate ordinary action, requiring compliance with formal evidentiary requirements not met in the agrarian case.