IGNACIA N. DE TANEDO, PETITIONER-APPELLANT, VS. EMETERIO DE LA CRUZ, RESPONDENT-APPELLEE.

This case, filed under the provisions of the Agricultural Tenancy
Act (R.A. No. 1199) is one for ejectment of the
leasehold tenant from the parcel of land under cultivation by him, owned by the
petitioners-appellants.  Judgment by the
Court of Agrarian Relations was for the respondent-appellee,
and appeal was taken to the Court of Appeals, which certified the same to us on
the ground that only a question of law is involved.

Several reasons were alleged in the complaint below to justify
the ejectment prayed for, but in this appeal only two
of said reasons are insisted upon, namely, failure on the part of the tenant to
pay the yearly rentals in advance pursuant to his agreement with the
landholders; and conviction of said tenant of a crime committed against them.

In the decision appealed from as well as in the resolution of the
Court of Appeals forwarding this case to us, it has been found that the rentals
for the agricultural years 1958 to 1961, inclusive, had all been fully
satisfied, although not in advance as agreed upon. This is admitted by the
petitioners-appellants.  We agree with
the Court a quo that the delay in payment does not justify the
drastic remedy of ejectment, considering Section
50(b) of Republic Act 1199, which states that while violation by the tenant of
any of the terms and conditions of the tenancy contract shall be a ground to
eject him, yet this provision shall not apply where there has been substantial
compliance.  With reference to the rental
for the crop-year 1962-63, failure to pay the same was not alleged in the
original or amended complaints below, and hence may not be considered for the
first time on appeal.

The second ground invoked by the petitioners-appellants deserves
more serious consideration.  It is an
admitted fact that the respondent-appellee was
charged with and convicted of the crime of theft by the Municipal Court of Tarlac for having stolen eight (8) bamboo shoots belonging
to the petitioners-appellants. The judgment of conviction was promulgated on April 27, 1962, and the penalty
imposed was a fine of P50.00.

The Agricultural Tenancy Act (R.A. No. 1199), which was then in
force, provided as follows:

“SEC. 50.  Causes for the
Dispossession of Tenant.  –
Any of the following, and no other, shall be sufficient cause for the
dispossession of a tenant from his hold­ings:

x          x          x

(g)  Conviction by a competent court of a tenant or
any member of his immediate family or farm household of a crime against the
landholder or a member of his immediate family.”

Several considerations deter this Court from applying the aforequoted provision to the letter in this case and
ordering the ejectment of the respondent-appellee as a result. 
First, the conviction was for a minor offense, involving as it did the
taking of a few bamboo shoots from the land under cultivation without the prior
consent of the petitioners-appellants, for which only a small fine was imposed
and duly paid. Second, under Section 49 of the Agricultural Tenancy Act, the
tenant shall be dispossessed of his holding for any of the causes enumerated in
Section 50 “only after the same has been proved before, and the
dispossession is authorized by the court.” It would seem from this
that the court is given some discretion to determine whether or not the cause,
although among those enumerated, is of such gravity as to warrant the drastic
remedy contemplated, or whether or not there exist circumstances under which
its application may be stayed.  Third, it
should be noted that under the Agricultural Land Reform Code (R.A. No. 3844,
approved August 8, 1963) an agricultural lessee’s conviction of a crime com­mitted
against his lessor is no longer a cause for the former’s dispossession. 
While the principle of retroactivity generally applied to posterior
legislation favorable to an accused refers to the penal aspects of the case,
yet for reasons of equity we believe that the benefits of that principle may be
extended to the respondent appellee here, insofar as
his ejectment is predicated on his conviction
alone.  Finally, Section 56 of the
Agricultural Tenancy Act lays down the guideline that “in the interpretation
and enforcement of this Act and other laws as well as of the stipulations
between the landholder and the tenant, the court and administrative officials
shall solve all grave doubts in favor of the tenant.” This Court has had
occasions to observe this guideline, among them in Santos
vs. Garcia, G.R. No. L-16894, May 31, 1963, where we reversed the decree of ejectment issued by the lower court on a finding that the
tenant had reaped two cavans of palay
from the land cultivated by him without the consent of the landholder.

Wherefore, the judgment appealed from is affirmed, without
costs.

Concepcion,
C.J., Reyes, J.B.L., Dizon, Zaldivar,
Castro, Fernando, Teehankee, Barredo,
and Villamor, JJ., concur.