G.R. No. L-855, November 21, 1902
HIJOS DE I. DE LA RAMA, plaintiffs-appellees, vs. VICENTE BENEDICTO, defendant-appellant.

FACTS:
The plaintiffs, Hijos de I. de la Rama, and the defendant, Vicente Benedicto, entered into a contract where the defendant would cultivate the plaintiffs’ land. The stipulated rent was an aliquot part (one-fourth) of the crop. The defendant failed to deliver a portion of the 1899 crop to the plaintiffs as required by their agreement. Consequently, the plaintiffs filed an action to eject the defendant from the land. The defendant raised a counterclaim, which was rejected by the trial court.

ISSUE:
Whether the defendant’s failure to deliver part of the crop as rent justified the plaintiffs’ action for ejectment under the Civil Code.

RULING:
Yes. The Supreme Court affirmed the judgment in favor of the plaintiffs. The Court held that the defendant’s failure to deliver the stipulated portion of the crop constituted a failure to pay rent. This breach gave the plaintiffs the right to eject the defendant under Article 1569, Section 2 of the Civil Code. The Court clarified that Article 1577 of the Civil Code, which might excuse certain failures, does not apply to a contract where the rent is a specific fractional share of the crop. The action was solely for ejectment based on non-payment of rent, not a personal action to recover the value of the undelivered crop. The timing of the suit (filed before the end of the subsequent crop year) was not a bar, as it was initiated after the defendant’s specific failure to deliver at the contractually specified time. The defendant’s counterclaim was properly rejected, and the record did not support the claim that the defendant had already abandoned the land.