Resuena v. Bas
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the ejectment of a tenant, Marcial Bas, from a landholding owned by spouses Gregorio and Epifania Resuena. The Resuenas sought to eject Bas on the grounds that they and their children intended to personally cultivate the land. Bas admitted to being the tenant since 1954 and raised counterclaims for reliquidation and moral damages. 2. Procedural History: The Resuenas' initial attempt to eject Bas through the Agricultural Tenancy Commission was dismissed due to a failure to comply with notice requirements. Subsequently, they filed a formal notice with the Court of Agrarian Relations and sent a letter to Bas, which he refused to accept but was later received via registered mail. After a year and repeated demands for possession, Bas refused to vacate, leading to the filing of CAR Case No. 362 (Cebu). The hearing commissioner denied a motion to dismiss, but the Agrarian Court ultimately dismissed the Resuenas' ejectment petition, finding they failed to establish good faith in their intention to personally cultivate the land. The court also dismissed Bas's counterclaims. The Resuenas' motion for reconsideration was denied, prompting this appeal by certiorari. 3. The Petition: The petitioners, Gregorio and Epifania Resuena, are appealing by certiorari the decision of the Court of Agrarian Relations. They contend that the lower court erred in holding that they failed to establish their good faith in seeking the ejectment of their tenant for personal cultivation. They argue that they, along with their sons Aldrico and Rogelio, are qualified to till the land and that the right to personal cultivation extends to female owners. The core issue is whether the petitioners have sufficiently demonstrated their bona fide intention to personally cultivate the landholding as required by Section 50(a) of Republic Act No. 1199, as amended.
Issue(s)
Whether the petitioners established their bona fide intention and good faith in seeking the ejectment of the respondent tenant for personal cultivation of their landholding. Whether the right to personal cultivation is limited to male owners or extends to female owners.
Ruling
The Supreme Court affirmed the decision of the Court of Agrarian Relations, dismissing the petition for ejectment. The Court found that the petitioners failed to establish their good faith and bona fide intention to personally cultivate the landholding. The counter-claim for damages by the respondent was also dismissed.
Ratio Decidendi
On the issue of bona fide intention and good faith for personal cultivation: The Court held that the petitioners failed to establish their good faith in seeking the ejectment of the respondent tenant for personal cultivation. Gregorio Resuena, one of the petitioners, was employed in Bohol and there was no indication he would participate in the cultivation. Epifania Resuena, the other petitioner, was a housewife whose role would be supervisory. Their son Aldrico, who was proposed to be the principal cultivator, was 27 years old, single, jobless, out of school, and dependent on his parents, with no evidence of any past farm work experience or knowledge of farming phases like plowing or harrowing. Furthermore, there was no showing that Aldrico possessed or had under his disposition any work animals or farm implements, which are indispensable for farming. The Court noted that petitioners had not explained why they chose this particular landholding for personal cultivation over four other landholdings they owned and leased to other tenants. The Court also found substance in the respondent's claim that the ejectment was motivated by the petitioners' resentment over the tenant's successful demand in 1958 to change the crop sharing from 50-50 to 70-30 in his favor. The Court reiterated the principle that the determination of a landowner's bona fide intention is largely a question of fact, and in this case, the Agrarian Court's finding lacked substantial basis in the evidence. On the issue of whether the right to personal cultivation extends to female owners: While the Court acknowledged the petitioners' contention that the right to personal cultivation is not limited to male owners, citing previous cases, this issue became moot because the primary issue of petitioners' failure to establish good faith and bona fide intention was not met. The Court's affirmation of the dismissal was based on the lack of evidence supporting the petitioners' capacity and genuine intent to cultivate the land themselves or through their son.
Main Doctrine
A landholder seeking to eject a tenant for personal cultivation must establish their bona fide intention and capacity to cultivate the land, supported by evidence of relevant experience and possession of necessary farm implements. Failure to demonstrate good faith in this endeavor warrants the dismissal of the ejectment petition.