GR L 14314; (February, 1961) (Digest)
G.R. No. L-14314; February 22, 1961
AGATON MATEO, petitioner, vs. GREGORIO DURAN and THE COURT OF AGRARIAN RELATIONS, SECOND REGIONAL DISTRICT, CABANATUAN CITY, respondents.
FACTS
Petitioner Agaton Mateo, a landlord, sought a review of the decision from the Court of Agrarian Relations (CAR) in a case filed by his tenant, respondent Gregorio Duran. Duran’s complaint was for the reliquidation of harvests from the agricultural years 1953-1954 to 1956-1957. The CAR found that the parties had been sharing the harvests on a 50-50 basis pursuant to their agreement. However, the court declared this sharing ratio void for being contrary to Section 11-A(a) of Republic Act No. 1199 (The Agricultural Tenancy Act). Consequently, the CAR ordered Mateo to deliver a deficiency of 93 cavans and 21 kilos of palay to Duran. Mateo appealed, contesting the factual findings, including the land area, total harvest, production expenses, and the classification of the land.
ISSUE
The primary issue is whether the factual findings and the consequent reliquidation ordered by the Court of Agrarian Relations are supported by substantial evidence and in accordance with law.
RULING
The Supreme Court affirmed the CAR’s factual determinations, finding them supported by substantial evidence. The Court upheld the finding that the landholding area was four hectares, based on the quantity of seedlings furnished and the number of transplanting laborers employed, rejecting Mateo’s claim of only two hectares. It also sustained the CAR’s conclusion that the tenant, Duran, shouldered the cost of transplanting under the “bayani” or “suyuan” system, where he provided food for helpers, and that the reaping expenses fixed at six cavans per cavan of seedlings were not unreasonable. The land was properly classified as second class based on the average harvest, and the Court approved the CAR’s detailed computation of the parties’ respective contributions, resulting in a 30-70 sharing ratio in favor of the tenant, not the 50-50 they practiced.
However, the Supreme Court modified the CAR’s decision regarding prescription. Applying Section 17, paragraph 3 of Republic Act No. 1199 , which requires an action for reliquidation to be brought within three years from threshing, the Court held that the claim for the 1953-1954 agricultural year had prescribed. Thus, Duran was entitled to a deficiency share only for the 1954-1955 to 1956-1957 crop years. The award was accordingly reduced to 69 cavans and 41.86 kilos of palay. The petition was partially granted, and the modified decision was affirmed without costs.