G.R. No. L-7738 May 30, 1955
BALDOMERO TACAD, ET AL., petitioners, vs. POTENCIANA VDA. DE CEBRERO, respondent.

FACTS

This is an appeal by certiorari from a decision of the Court of Industrial Relations. The decision authorized the ejectment of the petitioning tenants from their landholdings at the close of the 1953-1954 agricultural year and ordered the reliquidation of the 1952-1953 harvest on a 60-40 basis in favor of the respondent landowner. The ejectment was based on a finding that the tenants were guilty of disobedience and negligence for “concertedly disappearing on the appointed dates for threshing,” causing the landowner to incur damages by compensating the thresher and his crew. The petitioners disputed this factual finding, but the Supreme Court noted that factual findings by the Court of Industrial Relations are conclusive. The issue of reliquidation was submitted based on a stipulation of facts for the 1952-1953 agricultural year, which stated: (1) the landowner shouldered the planting expenses, furnished the seedlings, and shared equally in threshing expenses; (2) the tenants supplied farm implements and work animals, shouldered harvesting expenses (5 cavans per cavan of seedlings), and performed plowing and harrowing; and (3) the crop sharing basis was 50-50. The lower court, applying the formula from Sibulo vs. Altar, ordered a 60-40 reliquidation in favor of the landowner.

ISSUE

Whether the Court of Industrial Relations correctly applied the sharing formula from Sibulo vs. Altar to the stipulated facts in ordering the reliquidation of the 1952-1953 harvest.

RULING

The Supreme Court modified the decision of the Court of Industrial Relations regarding the reliquidation. It held that the lower court misapplied the Sibulo formula by crediting the landowner with the entire 30% allocated for planting and cultivation expenses. Based on the stipulation that the landowner only shouldered “the planting expenses,” and considering that cultivation (tilling, promoting growth, and care of plants) is a distinct operation, the Court reasoned that if no expense was incurred for cultivation, it must be assumed the tenant performed that work. Therefore, only one-half (15%) of the 30% for planting and cultivation expenses should be credited to the landowner. Applying the Sibulo formula to the stipulated contributions: the landowner is entitled to 30% for the land (capital) and 15% for planting expenses, totaling 45%. The tenant is entitled to 30% for labor (aside from cultivation), 15% for cultivation, 5% for work animals, and 5% for farm implements, totaling 55%. The ejectment order was affirmed, but the reliquidation basis was modified to 55-45 in favor of the tenants. No costs were awarded.