Santos v. Cerdenola
REITERATIONFacts
The Antecedents: Cecilia Lopez Vda. de Cerdenola and her late husband were tenants of a 10,000 sq. meter landholding in Hacienda Esperanza for over thirty years. After her husband's death in November 1952, she continued as tenant, complying with all conditions and requirements, and informing the overseer, Andres Cion. She continued to pay the landholder's shares from 1952 to 1957. In 1958, Jose Santos, the new administrator, ejected her and installed Juan Blanco as the new tenant. Cecilia Vda. de Cerdenola claimed unlawful ejectment, seeking reinstatement and damages. Procedural History: Cecilia Vda. de Cerdenola filed an action for reinstatement against Jose Santos and Juan Blanco. Respondent Juan Blanco denied the allegations and claimed her tenancy terminated upon her husband's death. Respondent Jose Santos also denied the allegations and asserted the termination of tenancy. After the petitioner presented part of her evidence, Juan Blanco moved to dismiss for insufficiency of evidence, which was denied. The court considered the case submitted for decision. Jose Santos' motion to reconsider this order was also denied. The Petition: Jose Santos filed a special civil action for certiorari with preliminary injunction, alleging that the Court of Agrarian Relations acted without jurisdiction and/or with grave abuse of discretion in ordering his participation without a "day in court" and in depriving him of the opportunity to pay damages without trial. He assailed the partial decision dated October 25, 1960, and the order of March 21, 1961.
Issue(s)
Whether the Court of Agrarian Relations acted without jurisdiction and/or with grave abuse of discretion in ordering petitioner's participation without a "day in court" and in depriving him of the opportunity to pay damages without trial. Whether the death of petitioner's husband terminates her tenancy relationship with the landholder. Whether petitioner can become a tenant for being a woman and of old age.
Ruling
The petition for certiorari is dismissed. The preliminary injunction is dissolved. The respondents are ordered to immediately reinstate the petitioner to her holding and to pay her jointly and severally damages equivalent to the landholder's share every year since 1958 until she is reinstated. The amount of damages was to be determined in a succeeding proceeding. Jose Santos was also ordered to pay P250.00 as attorney's fees.
Ratio Decidendi
On the procedural issues: The Supreme Court held that the petition for certiorari should be dismissed on the ground that the petitioner failed to exhaust available remedies in the lower court. Specifically, he did not file a motion for reconsideration of the orders he was assailing, which is a prerequisite for filing a certiorari petition under Section 1, Rule 67 of the Rules of Court. Furthermore, appeal was the proper remedy, as the petitioner had the opportunity to present his evidence but failed to act after his motion to set aside the order submitting the case for decision was denied. The partial decision became final and executory due to his inaction, and the subsequent final order regarding damages was also not appealed within the reglementary period. The Court emphasized that certiorari is not a substitute for appeal, especially when the petitioner's own fault led to the finality of the lower court's decisions. On whether the death of petitioner's husband terminates her tenancy relationship: The Supreme Court ruled that while the tenancy relationship might have been extinguished by the death of the tenant's husband under the original Section 9 of Republic Act 1199, the amendment introduced by Republic Act 2263 provided that in case of the tenant's death or incapacity, the tenancy relationship is continued with a member of the tenant's immediate farm household related within the second degree by consanguinity. The Court further elaborated that even if not related by consanguinity, the wife is considered an extension of the husband's personality, and their existence is a single moral, spiritual, and social being, especially for purposes of mutual help and protection. Moreover, the law allows a tenant to cultivate the land personally or with the aid of labor from members of his immediate farm household, and the wife's participation in planting, cleaning, harvesting, and winnowing constitutes part of the crop raising. The Court also noted that even if the tenancy was terminated by the husband's death, Cecilia Vda. de Cerdenola's continued cultivation of the land from 1952 to 1958, with the implied consent of the landholder's representatives, established an implied tenancy relationship under Section 7 of Republic Act 1199, granting her security of tenure. On whether petitioner can become a tenant for being a woman and of old age: The Supreme Court stated that the law does not make sex or age essential requirements for becoming a tenant. The law permits a tenant to cultivate the land either personally or with the aid of labor from members of their immediate farm household. Therefore, being a woman and of old age does not disqualify Cecilia Vda. de Cerdenola from being a tenant, especially since she could rely on the labor of her immediate farm household.
Main Doctrine
A tenancy relationship, once established, is entitled to security of tenure. Ejectment without lawful cause, particularly when it contravenes the provisions of the tenancy law, is unlawful. Tenancy may be established expressly or impliedly through the conduct of the parties.