ELENA P. VDA. DE REYES, FOR HERSELF AND AS GUARDIAN AD LITEM OF THE HEIRS OF HER DECEASED HUSBAND, SEVERINO REYES, PETITIONER, VS. COURT OF APPEALS, AND THE HEIRS OF PEDRO TABUB…

Vda. de Reyes versus Court of Appeals

The Case

This is a petition for review on certiorari, treated by the Supreme Court as a special civil action of certiorari, brought by Elena P. Vda. de Reyes, for herself and as guardian ad litem of the heirs of her deceased husband Severino Reyes, against the Court of Appeals and the heirs of Pedro Tabubuca. The dispute began as an agrarian case: Pedro Tabubuca sued to fix rentals and to reliquidate past harvests over a landholding in Cuyapo, Nueva Ecija, claiming to be a tenant-farmer. The case matters because it fixes a boundary on the protective mantle of Presidential Decree Number 316: the decree shields only bona-fide tenant-farmers, and a court may not suspend execution of a judgment in favor of a landowner when the claimant has been conclusively found not to be a tenant at all.

Procedural History

On November 24, 1970, Pedro Tabubuca filed before the Court of Agrarian Relations of Cuyapo, Nueva Ecija an action for fixing of rentals against the petitioner. On December 1, 1970, he amended the complaint to include as additional defendants the heirs of Severino Reyes and to seek reliquidation of past harvests. After trial, the Court of Agrarian Relations rendered judgment on October 30, 1973, dismissing the complaint for lack of merit and insufficiency of evidence, dissolving its interlocutory order that had allowed the plaintiff to possess and plant palay pending trial, declaring the plaintiff without any right to further possess or cultivate the landholding, and ordering him to deliver provisional rentals of 65 cavans of palay for the agricultural year 1971 to 1972 and 35 cavans of palay, or its equivalent in cash, as the balance for crop year 1972 to 1973.

The private respondents, who had substituted for the plaintiff upon his death, appealed to the Court of Appeals, raising principally whether Pedro Tabubuca was the bona-fide tenant-farmer on the land. On January 7, 1976, the Court of Appeals affirmed the decision appealed from but added that the decision shall not in the meantime be executed pursuant to Sections 1 and 3 of Presidential Decree Number 316. Its resolution of March 3, 1976 denied the motion for reconsideration. The petitioner then came to the Supreme Court by petition for review on certiorari, and the Court resolved to treat the petition as a special civil action of certiorari.

Facts

Pedro Tabubuca had been a tenant of the parents of Elena Reyes before 1966, under one Castro Pineda, but on another landholding in Cacapasan, Cuyapo, Nueva Ecija, and not on the landholding in question. That landholding, located in San Antonio, also in Cuyapo, was converted into a mango plantation by the Blue Ribbon Food's Corporation in 1966. The liquidation sheets he presented referred to different lands, situated in Curba and Cacapasan.

In November 1970, Tabubuca sued in the Court of Agrarian Relations to fix rentals and, by amendment, to reliquidate past harvests, impleading the heirs of Severino Reyes. Pending trial, the agrarian court allowed him to possess and plant palay on the landholding.

After trial, the agrarian court found that he was never a tenant on the land in 1966 and dismissed the complaint, dissolving the interlocutory order and requiring him to deliver the provisional rentals. The Court of Appeals affirmed the finding that he was not a bona-fide tenant-farmer, yet suspended execution of the judgment in the meantime under Presidential Decree Number 316. Hence the petition.

Issues

• Whether or not the Court of Appeals erred in suspending the execution of its decision pursuant to Sections 1 and 3 of Presidential Decree Number 316 despite its affirmance of the finding that Pedro Tabubuca was not a bona-fide tenant-farmer on the land in question.
• Whether or not Presidential Decree Number 316 applies in favor of a claimant who has been conclusively found not to be a bona-fide tenant-farmer.

Applicable Provisions

Section 1 of Presidential Decree Number 316 provides:

SECTION 1. No tenant-farmer in agricultural lands primarily devoted to rice and corn shall be ejected or removed from his farmholding until such time as the respective rights of the tenant-farmer and the landowner shall have been determined in accordance with the rules and regulations implementing Presidential Decree No. 27.

This is the provision the Court of Appeals invoked to suspend execution, and its text confines the protection to a tenant-farmer.

Section 3 of Presidential Decree Number 316 provides:

SECTION 3. In all cases, efforts shall be exerted by all government officials to maintain the status quo in the relation between tenant-farmer and the landowner as already embodied in Presidential instructions.

This provision presupposes an existing relation between tenant-farmer and landowner, which the courts below found did not exist over the land in dispute.

Presidential Decree Number 27 states:

This shall apply to tenant-farmers of private agricultural lands primarily devoted to rice and corn under a system of share-crop or lease-tenancy, whether classified as landed or not.

Because the decree reaches only tenant-farmers under a share-crop or lease-tenancy, it cannot benefit one who is not a tenant at all.

Ruling

On the first issue, the Court agreed with the petitioner. The Court of Appeals had affirmed in full the finding of fact that Pedro Tabubuca was not a bona-fide tenant-farmer on the land in question, and yet suspended execution under Presidential Decree Number 316. That suspension rendered the judgment ineffectual, meaningless, and nugatory, and the decree was erroneously applied.

On the second issue, the Court held that Presidential Decree Number 316, like Presidential Decree Number 27, applies and operates only in favor of bona-fide tenant-farmers. The Court declared:

It is already well settled that, like Presidential Decree No. 27, Presidential Decree No. 316 applies and operates only in favor of bona-fide tenant-farmers.

The Court further held that the finding of fact of the Court of Appeals that Pedro Tabubuca was not a bona-fide tenant-farmer on the land in question is final and conclusive, all the more so since the private respondents did not appeal from that decision. The Court expressly refrained from passing upon the constitutionality of Presidential Decree Number 316, because the point had not been specially pleaded, insisted upon, and adequately argued.

Doctrine

A Bar candidate should retain these rules. First, Presidential Decree Number 316, like Presidential Decree Number 27, applies and operates only in favor of bona-fide tenant-farmers; it does not protect a claimant whom the courts have found not to be a tenant. Second, the protection of Section 1, which bars ejection or removal of a tenant-farmer until the respective rights of the parties are determined under the rules implementing Presidential Decree Number 27, and of Section 3, which directs government officials to maintain the status quo in the relation between tenant-farmer and landowner, presupposes that such a relation exists. Third, a finding of fact of the Court of Appeals, especially when unappealed, is final and conclusive and may not be disturbed. Fourth, a court may not suspend execution of a judgment on the strength of a statute whose operative fact — here, bona-fide tenancy — has been negated by its own affirmed findings.

Disposition

The petition was granted; the portion of the judgment of the Court of Appeals suspending execution under Sections 1 and 3 of Presidential Decree Number 316 was deleted, and the decision of the former Court of Agrarian Relations was declared final and executory.

Remember This

Memorize the line: Presidential Decree Number 316, like Presidential Decree Number 27, applies and operates only in favor of bona-fide tenant-farmers. Examiners use this case to test the coverage of agrarian tenant-protection decrees and the conclusiveness of an unappealed finding of fact that a claimant is not a bona-fide tenant.