G.R. No. L-5175 February 27, 1953
CATALINO CAMIA ET AL., vs. FELIPE CHANCO and the COURT OF INDUSTRIAL RELATIONS

FACTS

Petitioners are tenants of respondent Felipe Chanco, the lessee of two haciendas in Cuyapo, Nueva Ecija. They had tenancy contracts for the agricultural year 1949-1950 but refused to sign the contracts offered for 1950-1951. Chanco filed complaints with the Tenancy Law Enforcement Office, seeking their ejection. The tenants answered, expressing willingness to sign contracts under a 55-45 sharing ratio in their favor, with planting and cultivation expenses shared equally. The cases reached the Court of Industrial Relations (CIR) to determine the disputed expenses. Chanco presented evidence that the cost of planting, cultivation, and harvesting was P40 per cavan of seedlings, while the tenants claimed total expenses of P96 (P651 for planting/cultivation, P25 for harvesting, P10 for bundling). Judge Arsenio Roldan of the CIR fixed the total reasonable cost at P50 for the year, to be shared equally. The tenants moved for reconsideration, arguing the decision failed to separately determine the cost of harvesting, which by law should be deducted from the gross produce. The CIR en banc affirmed the decision by a 3-2 vote, prompting this certiorari action.

ISSUE

Whether the Court of Industrial Relations acted illegally by fixing a single monetary amount for the combined expenses of planting, cultivation, and harvesting, instead of separately determining the harvesting expenses to be deducted from the gross produce as required by Republic Act No. 34.

RULING

The Supreme Court reversed the CIR order. The Court held that fixing the cost of harvesting in a specific peso amount, jointly with other expenses, contravenes Republic Act No. 34, which expressly provides that “expenses for harvesting and threshing shall be deducted from the gross produce.” This provision intends to grant the tenant the right to personally perform the harvesting, thereby increasing his share, providing him with immediate livelihood before crop division, and reducing his need for cash outlays or borrowing. The Court emphasized that allowing a fixed monetary amount for harvesting deprives the tenant of these advantages, potentially forces him into unfavorable borrowing, enables the landlord to share in what the law reserves for the tenant, and opens new grounds for litigation to the tenant’s disadvantage. The record showed the tenants never consented to having harvesting expenses fixed in pesos; they only agreed to share planting and cultivation costs. The case was remanded to the CIR for proceedings consistent with this opinion.