GR 27667; (March, 1970) (Digest)
G.R. No. L-27667 March 25, 1970
IGNACIA N. DE TANEDO, petitioner-appellant, vs. EMETERIO DE LA CRUZ, respondent-appellee.
FACTS
The petitioner-appellant, Ignacia N. de Tanedo, filed a case for ejectment against her leasehold tenant, respondent-appellee Emeterio de la Cruz, under the Agricultural Tenancy Act ( R.A. No. 1199 ). The Court of Agrarian Relations ruled in favor of the tenant, and the appeal was certified to the Supreme Court by the Court of Appeals as it involved only a question of law. The appellant insisted on two grounds for ejectment: (1) the tenant’s failure to pay yearly rentals in advance as agreed, and (2) the tenant’s conviction of a crime against the landholder. It was found that rentals for 1958 to 1961 were fully paid, though not in advance, and the failure to pay the 1962-63 rental was not alleged in the complaints below. The tenant was convicted of theft for stealing eight bamboo shoots belonging to the appellant, with a penalty of a P50.00 fine promulgated on April 27, 1962.
ISSUE
Whether the tenant’s conviction for theft of bamboo shoots and his delayed rental payments constitute sufficient grounds for his ejectment under the Agricultural Tenancy Act.
RULING
The Supreme Court affirmed the judgment against ejectment. On the first ground, the delay in rental payments did not justify ejectment under Section 50(b) of R.A. No. 1199 , as there was substantial compliance, and the 1962-63 rental issue could not be raised for the first time on appeal. On the second ground, the Court declined to apply Section 50(g) of the Act strictly, which allowed dispossession for conviction of a crime against the landholder, due to several considerations: the conviction was for a minor offense with a small fine; Section 49 implied judicial discretion in authorizing dispossession; the subsequent Agricultural Land Reform Code ( R.A. No. 3844 ) removed such conviction as a ground for dispossession, and equity favored extending this beneficial principle; and Section 56 of the Act required resolving grave doubts in favor of the tenant. Thus, ejectment was not warranted.