Bermudez v. Fernando
REITERATIONFacts
1. The Antecedents: Petitioners Angel Bermudez and Isabelo Sampaga were tenants of respondent Margarita Fernando under share tenancy contracts for the agricultural year 1958-1959, with a 50-50 sharing system and the respondent covering transplanting expenses. These contracts were not renewed for the 1960-1961 agricultural year. 2. Procedural History: In August 1960, petitioners refused sums tendered by the respondent for transplanting expenses. Consequently, on September 15, 1960, the respondent consigned these amounts with the Court of Agrarian Relations (CAR Case No. 2188-NE'60), seeking to compel the petitioners to accept them. The petitioners' answer claimed they had notified the respondent of their desire to change to leasehold tenancy and had already defrayed the transplanting expenses. After trial, the CAR declared the respondent had defrayed the expenses, ordered the release of the consigned funds to the petitioners, and ordered the respondent to pay additional sums to each petitioner. 3. The Petition: The petitioners appealed the decision of the Court of Agrarian Relations to the Supreme Court. They argued that they had notified the respondent of their intent to switch to leasehold tenancy and had already paid for the transplanting expenses. The Supreme Court affirmed the lower court's findings, noting that the CAR found no sufficient evidence for the claimed notification of leasehold tenancy and that the tender of expenses was made before the transplanting season began, a finding supported by substantial evidence.
Issue(s)
Whether the petitioners sufficiently proved their notification to the respondent of their desire to change the tenancy system to leasehold. Whether the petitioners had already defrayed the transplanting expenses when the respondent tendered the amounts.
Ruling
The decision of the Court of Agrarian Relations is affirmed.
Ratio Decidendi
On the issue of notification to change tenancy system: The Supreme Court affirmed the finding of the respondent court that there was no sufficient evidence to support the petitioners' claim of notifying the respondent of their desire to change their tenancy system to leasehold tenancy. The Court noted that this contention was not even mentioned by the petitioners in their respective testimonies during the trial. This lack of substantiation meant that the petitioners failed to discharge their burden of proof regarding this crucial aspect of their claim. Therefore, the lower court's factual finding on this matter was upheld. On the issue of defraying transplanting expenses: The Supreme Court upheld the lower court's finding that the respondent had effectively defrayed the transplanting expenses. This was based on the finding that the respondent's tender of the amounts for transplanting expenses was made "before the commencement of the transplanting season in the place where the landholdings in question are located." This timing indicated that the respondent had acted in accordance with her obligation to provide for these expenses prior to the actual need arising. Consequently, the petitioners' claim that they had already incurred these expenses themselves when the tender was made was not given credence.
Main Doctrine
The findings of fact of the Court of Agrarian Relations are binding and may not be reversed on appeal if supported by substantial evidence on record.