Verde v. Macapagal
REITERATIONFacts
The Antecedents: Vicente F. Macapagal and Irenea R. Estrella owned a 2.5-hectare agricultural land (Lot No. 4714) in Bulacan. Upon their demise, the land passed to their children (respondents). Petitioner Celso Verde is the leasehold tenant, having succeeded his father. Respondents initiated an ejectment case against petitioner, alleging that in 1993, petitioner mortgaged the land to Aurelio dela Cruz, who then worked on half of the property. Petitioner admitted the mortgage, promised to redeem it, and assured respondents he would not mortgage the property again. However, dela Cruz still farmed the land in 1994. Respondents argued this constituted abandonment, a ground for termination of leasehold under R.A. No. 3844. Conciliation efforts at the Barangay Agrarian Reform Council (BARC) were unsuccessful. Procedural History: The Provincial Agrarian Reform Adjudication Board (PARAB) dismissed the ejectment case, ruling that petitioner did not "actually and absolutely" abandon his tenancy, as he intended to cultivate the other half of the property and the alleged mortgage was a personal loan due to financial need. The PARAB also noted the self-serving nature of affidavits submitted by respondents and the failure of their affiants to testify. The Department of Agrarian Reform Adjudication Board (DARAB) affirmed this ruling. The Court of Appeals reversed the DARAB decision, holding that petitioner’s act of mortgaging the land and allowing dela Cruz to till it violated the prohibition against subtenants and the requirement of personal cultivation. The appellate court cited jurisprudence stating that personal cultivation must be by the tenant, his immediate farm household, or dependents. Petitioner filed a petition for certiorari with the Supreme Court. The Petition: Petitioner argued that as a bona fide tenant with 20 years of cultivation, he could not be dispossessed based on conjecture. He assailed the Court of Appeals' reliance on the joint sworn statement of Sanciangco and Cruz, claiming dela Cruz's affidavit refuted it. Petitioner also argued that any agreement to mortgage real rights of a leasehold tenant must be in writing under the statute of frauds and that respondents failed to prove abandonment, as no notice of abandonment was given as required by R.A. No. 3844.
Issue(s)
Whether the Court of Appeals erred in declaring that petitioner did not personally cultivate the subject land, thereby justifying his ejectment therefrom. Whether the mortgaging of the landholding and allowing another to till it constitutes abandonment of the agricultural leasehold relation; and whether the Court of Appeals erred in giving credence to the joint sworn statement of Sanciangco and Cruz.
Ruling
The Supreme Court reversed and set aside the decision of the Court of Appeals and reinstated the decision of the DARAB. The Court found that the petitioner did not abandon his agricultural leasehold relation and that the hiring of Aurelio dela Cruz was due to the petitioner's temporary incapacity to perform certain farm tasks, specifically the use of a carabao, which he could not afford to own. Dispositive Portion: WHEREFORE, premises considered, the Decision of the Court of Appeals dated 18 December 2001 is hereby REVERSED and SET ASIDE and the Decision of the DARAB dated 30 October 2000 is REINSTATED. No costs.
Ratio Decidendi
On the Issue of Personal Cultivation and Abandonment: The Court held that the element of personal cultivation in an agricultural leasehold relationship does not strictly mean that the tenant must perform every single farm task personally. The law defines personal cultivation as cultivation by the lessee or lessor in person and/or with the aid of labor from within his immediate household. However, the Court clarified that employing farm laborers on a temporary or occasional basis does not negate this element, especially if the tenant generally works the land himself or with his immediate household. In this case, the petitioner hired Aurelio dela Cruz and his carabao because he lacked the means to own one during the agricultural seasons of 1993 and 1994. This situation was considered an "incapacity" under Section 27(2) of Rep. Act No. 3844, which permits the agricultural lessee to avail himself of the services of laborers in case of illness or temporary incapacity. The Court distinguished this from cases where tenants hired numerous laborers or were found to be businessmen cultivating multiple fishponds, which indicated a lack of personal involvement. The Court found that the evidence presented primarily focused on dela Cruz's involvement, suggesting his services were engaged specifically for the use of his carabao, which the petitioner could not afford. Therefore, the petitioner's actions did not constitute abandonment of his leasehold rights or a breach of the personal cultivation requirement. On the Issue of Abandonment and the Admissibility and Weight of Evidence: The Court addressed the petitioner's contention that the Court of Appeals erred in giving credence to the joint sworn statement of Sanciangco and Cruz. While acknowledging that technical rules of procedure are relaxed in agrarian cases, the Court highlighted that the petitioner had ample opportunity to challenge the contents of these affidavits. The provincial adjudicator had set hearings for clarificatory questions, but the petitioner failed to appear on multiple occasions. Given these circumstances, the petitioner could not subsequently complain about the weight given to the affidavits, as he was afforded the chance to confront the affiants or present counter-evidence but failed to do so. Despite this, the Court ultimately found merit in the petition based on the substantive issue of personal cultivation and abandonment.
Main Doctrine
The mere hiring of farm laborers to perform some aspects of farm work, such as the use of a carabao, does not necessarily negate the existence of an agricultural leasehold relationship, provided the tenant does not relinquish the entire process of cultivation to hired helpers. Temporary or occasional assistance does not breach the requirement of personal cultivation, especially when the tenant demonstrates incapacity to perform certain tasks due to lack of resources.