Ulpiendo v. Court of Agrarian Relations
REITERATIONFacts
The Antecedents: This case concerns a dispute over agricultural tenancy relationships. Petitioners Joaquin Ulpiendo, Vicente Joves, Dalmacio Dadural, Catalina Doyanen, and Jose Ragudo sought recognition as tenants on lands owned by respondents Armando Lim and Pedro de la Cruz. They prayed for a 70-30 produce sharing basis and the execution of formal tenancy contracts. The underlying issue involved whether these individuals were legitimate tenants or merely helpers ('kasugpons') of the actual tenants, who were either deceased or had left their landholdings. Procedural History: The petitioners initially filed their case in the Court of Agrarian Relations (CAR). The CAR, in a decision dated July 22, 1957, recognized tenancy relationships for all petitioners and ordered the respondents to maintain them as tenants, with specific directives regarding the distribution of harvested palay. However, a motion for reconsideration led to a modified judgment on November 26, 1957, where the CAR dismissed the petition for Dalmacio Dadural, Catalina Doyanen, and Jose Ragudo, while affirming the judgment for Joaquin Ulpiendo and Vicente Joves. Further motions for reconsideration resulted in a resolution on April 21, 1958, which reversed the earlier affirmation for Ulpiendo and Joves, dismissed the petitioners' complaint entirely, and affirmed the November 26, 1957 resolution regarding Dadural, Doyanen, and Ragudo. The case then proceeded to this Court via a petition for review. The Petition: The petitioners, excluding Jose Layno, filed this petition for review under Republic Act No. 1267, as amended by Republic Act No. 1409, challenging the CAR's resolutions of November 26, 1957, and April 21, 1958. They primarily raised procedural questions, arguing that the respondents' motion for reconsideration of the July 22, 1957 decision was filed out of time, thereby divesting the CAR of jurisdiction. Specifically, they contended that the 15-day extension granted to the respondents to file their motion for reconsideration had already expired when the motion was mailed. Additionally, they argued that a second motion for reconsideration filed by the respondents should not have been entertained as it was also untimely and reiterated grounds already considered. The petition also addressed subsequent developments, including the alleged abandonment of his landholding by Jose Ragudo and the status of Pedro de la Cruz as a mere overseer.
Issue(s)
Whether the respondent Court of Agrarian Relations lost jurisdiction to reconsider its decision dated July 22, 1957, due to the alleged untimeliness of the respondents' motion for reconsideration. Whether the respondent Court of Agrarian Relations erred in entertaining the respondents' second motion for reconsideration concerning petitioners Ulpiendo and Joves. Whether the petitioners Dalmacio Dadural and Catalina Doyanen were tenants or merely helpers ('kasugpons') of the respondents. Whether the tenancy relationship of Pedro Dadural and Fernando Gasmin was extinguished by their death, and if their heirs (petitioners Dalmacio Dadural and Catalina Doyanen) could claim tenancy rights.
Ruling
The Supreme Court affirmed the resolutions of the Court of Agrarian Relations dated November 26, 1957, and April 21, 1958, concerning petitioners Dalmacio Dadural and Catalina Doyanen. It set aside the part of the April 21, 1958 resolution concerning petitioners Vicente Joves and Joaquin Ulpiendo and reinstated the resolution of November 26, 1957, which had become final. The petition for review of petitioner Jose Ragudo was dismissed without prejudice to his right to receive his share of the produce. The case against respondent Pedro de la Cruz was dismissed.
Ratio Decidendi
On the timeliness of the respondents' first motion for reconsideration: The Court held that the respondents' motion for reconsideration was filed within the extension granted. The computation of the 15-day extension, excluding the first day (August 15) and including the last day (August 30), meant that only 15 days had elapsed when the motion was mailed. This adhered to Rule 28 of the Rules of Court, which adopts the exclude-the-first-and-include-the-last-day method for computing time periods. Therefore, the CAR did not lose jurisdiction. On the entertainment of the respondents' second motion for reconsideration: The Court ruled that the CAR had no jurisdiction to pass upon the respondents' second motion for reconsideration concerning petitioners Vicente Joves and Joaquin Ulpiendo. This was because the ground relied upon in the second motion was available at the time of the first motion and was merely a reiteration. Furthermore, after the denial of their first motion, the respondents' remedy was a petition for review in the Supreme Court within 15 days, not a second motion for reconsideration. On the tenancy of Dalmacio Dadural and Catalina Doyanen: The Court found that Dalmacio Dadural was merely a helper ('kasugpon') of his father, Pedro Dadural, who was the actual tenant. Upon Pedro Dadural's death, Dalmacio, as heir, could only continue working until the end of the agricultural year, as provided by Section 9 of Republic Act No. 1199. His continued stay thereafter without the landowner's consent was unauthorized. Similarly, Catalina Doyanen was a helper ('kasugpon') of her husband, Fernando Gasmin, the tenant. Upon Fernando's death, she was allowed to continue until the end of the agricultural year, but she did not acquire tenancy rights. The evidence, including liquidation sheets and receipts, consistently showed Pedro Dadural and Fernando Gasmin as the tenants, not their heirs. On the extinguishment of tenancy by death: The Court reiterated that tenancy relationship is extinguished by the death of the tenant, although heirs or members of the immediate farm household may continue working the land until the close of the agricultural year. In this case, Pedro Dadural and Fernando Gasmin were the tenants. Upon their deaths, their heirs, Dalmacio Dadural and Catalina Doyanen, were merely permitted to finish the agricultural year. They could not, as a matter of right, demand recognition as tenants. The amendment to Section 9 of Republic Act No. 1199, which allowed for the continuance of tenancy with a member of the tenant's immediate farm household, was not applied retroactively as it took effect after the events in question.
Main Doctrine
The Court of Agrarian Relations has the discretion to grant extensions for filing motions for reconsideration, provided such extensions are for valid reasons and not attended by grave abuse of discretion. The computation of time for filing motions for reconsideration must strictly adhere to the Rules of Court, excluding the first day and including the last. A second motion for reconsideration is generally not allowed unless based on a ground not existing at the time of the first motion. Tenancy relationship is extinguished by the death of the tenant, though heirs may continue working the land until the close of the agricultural year, but they do not automatically acquire tenancy rights.