G.R. No. L-44678 April 8, 1986
FRANCISCO BALIGWAT, petitioner, vs. HON. COURT OF APPEALS and ALBINO ESTAVOS, respondents.

FACTS

Petitioner Francisco Baligwat was the agricultural tenant of private respondent Albino Estavos over 1.5 hectares of coconut land in Lanao del Norte. Estavos sought to eject Baligwat on the ground of personal cultivation, complying with the procedural requirements under the Agricultural Tenancy Act ( Republic Act No. 1199 ) by sending a notice of termination one year before filing the ejectment case in April 1972. Estavos, who was jobless and had farming experience, intended to personally cultivate the tenanted portion of his 26-hectare coconut property.
Baligwat moved to dismiss the complaint, arguing that the ground of personal cultivation by the landowner had been repealed by Section 7 of Republic Act No. 6389 , which amended the Code of Agrarian Reforms ( Republic Act No. 3844 ). The Court of Agrarian Reforms denied his motion, a decision affirmed by the Court of Appeals. Both lower courts held that the repeal did not apply to coconut lands. Baligwat elevated the case to the Supreme Court via petition for review.

ISSUE

Whether personal cultivation by the landowner remains a valid ground for ejecting a tenant from a landholding principally planted to coconut trees.

RULING

The Supreme Court affirmed the decision of the Court of Appeals, ruling that personal cultivation is still a valid ground for dispossession for lands devoted to permanent trees like coconuts. The legal logic hinges on the specific exemptions carved out by agrarian laws. While Republic Act No. 6389 indeed deleted “personal cultivation” as a ground for dispossession under the general leasehold system established by Republic Act No. 3844 , this amendment does not universally apply.
Critical to the resolution is Section 35 of Republic Act No. 3844 , which explicitly states that for lands principally planted to citrus, coconuts, cacao, coffee, durian, and similar permanent trees, the tenancy system and the considerations governing it shall continue to be governed by the provisions of Republic Act No. 1199 , as amended. Since personal cultivation is a ground for dispossession under Section 50 of Republic Act No. 1199 , it remains operative for coconut lands. This exemption is reinforced by Section 1 of Presidential Decree No. 1425, which maintains the leasehold system for other crops with the exceptions provided in Sections 4 and 35 of the Code.
The Court rejected the petitioner’s reliance on the Arambulo case, noting it involved riceland and, more importantly, that its reasoning had been effectively reversed by the en banc ruling in Nilo v. Court of Appeals, which held that Republic Act No. 6389 could not be applied retroactively. Consequently, for tenanted coconut lands, the regime of Republic Act No. 1199 persists, and personal cultivation by the owner- lessor remains a legitimate ground for termination of the tenancy relationship. The petition was dismissed.