Coconut Cooperative Marketing Association, Inc. v. Court of Appeals
REITERATIONFacts
The Antecedents: The owners of a 15-hectare coconut land in Laguna executed yearly contracts of sale (pakyaw) of their produce with Rosario Paraiso Vda. de Fule (Fule) from prior to 1964 up to 1971, and subsequently with Eddie A. Escudero from 1972 to 1975. Prior to 1964, Fule utilized the services of Pedro, Hermogenes, and Lucas Cosico as caretakers for four hectares each, paying them in cash equivalent to 1/7 of the proceeds from the sale of coconuts harvested from their respective areas. As caretakers, their tasks included checking for theft, reporting to Fule, and clearing the land by cutting grass and burning them. They lived 2.5 kms. away and used bolos for clearing. They alleged planting coconut and other trees without payment. Harvesting, gathering, picking, and hauling were done by laborers hired and paid by Fule or her buyer. Pedro Cosico was paid separately for gathering coconuts. Fule was a member of petitioner COCOMA from 1964 to 1972, and Escudero from 1972 to 1975. COCOMA claims to have acted as agent for Fule and Escudero, providing management and marketing services, and hiring laborers for harvesting and transport. Pedro and Hermogenes Cosico were hired as cleaners on COCOMA's recommendation. Expenses were approved and paid by Fule and Escudero through COCOMA. Procedural History: On October 9, 1971, Pedro, Hermogenes, and Lucas Cosico claimed to be tenants and filed CAR Cases Nos. 2236, 2237, and 2238 against Fule and Villa Escudero Corporation (VESCO). COCOMA was later added as a defendant. The Court of Agrarian Relations (CAR) rendered a joint decision on January 26, 1976, declaring Pedro and Hermogenes Cosico as true and lawful tenants of COCOMA over four hectares each, but finding no tenancy relation with Lucas Cosico. COCOMA was ordered to reinstate Pedro and Hermogenes, maintain their peaceful possession, and pay them 30% of the net harvest from November 12, 1971, to June 4, 1975, and render an accounting thereafter. COCOMA was also ordered to pay litigation expenses. COCOMA appealed to the Court of Appeals (CA). On May 19, 1977, the CA affirmed the CAR decision in toto. The Petition: COCOMA filed a petition for review on certiorari with the Supreme Court, raising four issues: (1) whether respondents are share tenants; (2) whether Hermogenes Cosico could be declared a tenant in Lucas Cosico's case when he was not a party and did not claim such tenancy; (3) whether COCOMA, as a mere agent, could be held directly liable; and (4) whether the computation of shares was erroneous.
Issue(s)
Whether the private respondents are share tenants in the coconut landholdings. Whether Hermogenes Cosico can be declared a share tenant in the landholding subject of CAR Case No. 2238, where Lucas Cosico was the plaintiff, despite Hermogenes not being a party to that case and not alleging tenancy therein. Whether COCOMA, as a mere marketing agent, can be held directly liable to the private respondents-tenants for their share in the harvested coconuts. Whether the computation of the private respondents' shares by the lower courts is patently erroneous.
Ruling
The petition is DENIED. The decision of the Court of Appeals is AFFIRMED.
Ratio Decidendi
On the issue of whether the private respondents are share tenants: The Court held that the private respondents are share tenants, not mere agricultural workers. The Court distinguished between a share tenant and an agricultural worker, emphasizing that share tenancy involves the physical possession of land for production through the labor of the tenant in consideration of sharing the harvest, while an agricultural worker is an employee with an employer-employee relationship characterized by selection, payment of wages, power of dismissal, and the employer's power of control. The Court found that the respondents did not observe regular hours, work in shifts, or have prescribed work regulations, and that COCOMA lacked the degree of control and supervision essential for an employer-employee relationship. Furthermore, the Court emphasized that cultivation, which includes the care of plants and husbanding the ground to forward products, is a key factor in determining share tenancy. The Court found that the respondents' work, including clearing the land, planting, and tending to the coconut trees (which involves smudging, fertilizing, and weeding for increased produce), constituted cultivation. The sharing of the produce on a 1/7 to 6/7 basis further supported the existence of a share tenancy relationship. The Court also noted that findings of fact by the Court of Appeals, such as the nature of the relationship, are generally conclusive and entitled to respect. On the issue of Hermogenes Cosico's tenancy in Lucas Cosico's landholding: The Court found the petitioner's contention to be without merit. The three cases were jointly tried, and common evidence showed that although Hermogenes and Lucas Cosico were supposed to have separate holdings, they worked the two holdings jointly from 1956, with Hermogenes receiving the tenant's share from the entire area. Thus, Hermogenes acted as the sole tenant of both holdings, warranting his recognition as such by the courts. The Court cited Teodoro vs. Macaraeg to support the principle that the Court of Agrarian Relations is not restricted to specific relief claimed but may determine matters expedient for settling disputes, provided they are established by competent evidence. The Court also referenced Section 155 of R.A. 3844, which allows the Courts of Agrarian Relations to be less bound by technical rules of procedure and evidence to achieve substantial justice. On the issue of COCOMA's liability as a mere agent: The Court ruled that COCOMA is liable as a landholder, not merely an agent. The definition of a landholder under Section 5(b) of R.A. 1199 includes a juridical person who, as legal possessor, lets or grants to another the use or cultivation of land for a consideration. The Court found COCOMA to be a juridical person, the legal possessor with sole management and administration of the land, who authorized the respondents to cultivate it and shared the harvest with them. Therefore, COCOMA was subject to agrarian laws. The Court also invoked Section 10 of R.A. 3844, stating that the agricultural leasehold relation is not extinguished by the transfer of legal possession, and the purchaser or transferee is subrogated to the rights and obligations of the agricultural lessor. Citing Primero v. CAR, Joya v. Pareja, and Almarinez v. Potenciano, the Court reiterated that the tenancy relationship should be preserved in cases of transfer of legal possession to protect the tenant's security of tenure. Thus, COCOMA, as a transferee or legal possessor, could be held liable to the private respondents for their shares. On the issue of the computation of shares: The Court found no compelling reason to depart from the computation made by the Court of Agrarian Relations and affirmed by the Court of Appeals. The Court reiterated the rule that findings of fact by the CA are conclusive on appeal unless they are unfounded, arbitrarily arrived at, or fail to consider important evidence. Citing Bagsican v. Court of Appeals, the Court stated that in agrarian cases, only substantial evidence is required, and the appellate court's role is to determine if the decision is supported by such evidence. The CA correctly ruled that it was not at liberty to reverse the findings of fact of the Agrarian Court without proof of error, as the findings were supported by substantial evidence.
Main Doctrine
The Court affirmed the Court of Appeals' decision, holding that the private respondents were share tenants, not mere agricultural workers, based on the nature of their work, the sharing of harvests, and the absence of the elements of an employer-employee relationship, particularly the element of control. The petitioner, COCOMA, was deemed a landholder and thus liable for the tenants' shares.