TRINIDAD YAPTANGCO VDA. DE TIZON, PETITIONER, VS. DOMINGO M. CABAÑGON, AS JUDGE OF THE COURT OF AGRARIAN RELATIONS, THIRD REGIONAL DISTRICT, AND ROMUALDO DAVID, RESPONDENTS.

Trinidad Yaptangco Vda. de Tizon versus Domingo M. Cabañgon and Romualdo David

The Case

This is a petition brought by Trinidad Yaptangco Vda. de Tizon, a landholder in Sto. Tomas, Pampanga, against Judge Domingo M. Cabañgon of the Court of Agrarian Relations and against her tenant, Romualdo David. The landholder asks the Supreme Court to undo the agrarian court's rulings fixing the sharing ratio in the rice harvest and ordering a reliquidation of past crops. The case matters because it settles two questions every agrarian law examinee must know: whether separate landholdings held by one tenant are classified as one unit or each on its own, and whether a correction of the sharing ratio to match the tenant's actual contributions is a change of tenancy contract that Section 14 of the Agricultural Tenancy Act governs.

Procedural History

Romualdo David filed a verified petition with the Court of Agrarian Relations, praying that the 1959 to 1960 crop be divided at a higher ratio in his favor and that the produce of earlier crop years be reliquidated. The agrarian court issued an interlocutory order for the deposit and partial delivery of the harvest, which was carried out. After trial, the agrarian court rendered decision on February 8, 1962, classifying the San Bartolome land as second class and the Sto. Tomas land as first class, fixing the sharing ratios accordingly, and ordering reliquidation for the crop years 1956 to 1957, 1957 to 1958, and 1958 to 1959. On the landholder's motion, the agrarian court modified the judgment on April 13, 1962, reducing the award to 22.175 cavans of palay and applying a 57.5 to 42.5 sharing for the Sto. Tomas land in the earlier years, because that was all the tenant had prayed for. The landholder then appealed to the Supreme Court, which decided the case in January 1967.

Facts

Since 1942, Romualdo David had been the tenant of Trinidad Yaptangco Vda. de Tizon on two landholdings in Sto. Tomas, Pampanga. The first, in Barrio San Bartolome, had an area of 2.0853 hectares. The second, consisting of two lots, had a total area of 2.3662 hectares. Ursula Raquis managed the lands until 1959, when the landholder took direct charge. The produce was divided 55 percent to the tenant and 45 percent to the landholder.

On February 8, 1960, the tenant went to the Court of Agrarian Relations. He asked that the 1959 to 1960 crop, just harvested, be divided at 62.5 to 37.5 in his favor for San Bartolome and 70 to 30 for Sto. Tomas, and that the crops of the five preceding years be reliquidated on the same basis. The agrarian court found that the tenant contributed all the labor, farm implements, and work animals, and bore all the expenses except one half of the transplanting in San Bartolome. It classified San Bartolome as second class land and Sto. Tomas as first class land, and ordered reliquidation for the last three crop years only, the earlier years being barred.

The landholder appealed. She argued that the two landholdings should be treated as one unit for classification, that the change in sharing for the 1959 to 1960 crop violated Section 14 of the Agricultural Tenancy Act because it came mid-year, and that she was not the landholder during the earlier crop years, her aunt Ursula Raquis having managed the farms.

Issues

• Whether or not, for purposes of classifying ricelands held in tenancy by one tenant, the production of each separate landholding should be taken into account, rather than the sum total of all areas held.
• Whether or not the correction of the sharing ratio for the 1959 to 1960 crop to match the parties' actual contributions is a change of crop-sharing arrangement governed by Section 14 of the Agricultural Tenancy Act, which may be exercised only at the end of the agricultural year.
• Whether or not the landholder may escape reliquidation for the earlier crop years on the plea that she was not the landholder during those years.

Applicable Provisions

Section 32 of the Agricultural Tenancy Act provides the share basis on first class ricelands:

SEC. 32. Share Basis. - The parties shall, on ricelands which produce a normal average of more than forty cavanes per hectare for the three agricultural years next preceding the current harvest, receive as shares in the gross produce, after setting aside the same amount of palay used as seed, and after deducting the cost of fertilizer, pest and weed control, reaping and threshing, the amount corresponding to the total equivalent of their individual contributions, computed as follows: 1. Land 30% 2. Labor 30% 3. Farm implements 5% 4. Work animals 5% 5. Final harrowing of the field immediately before transplanting 5% 6. Transplanting 25%

This provision fixes the sharing on first class land, which the Court applied to the Sto. Tomas landholding.

Section 33 of the same Act provides the share basis on second class land:

SEC. 33. Share Basis on Second Class Land. - On ricelands, which produce a normal average of forty cavans or less per hectare for the three agricultural years next preceding the current harvest, the participation for the contribution of the land shall be twenty-five per centum and that of labor, thirty five per centum.

This provision governs the San Bartolome landholding, which the Court found produced less than forty cavanes per hectare.

Section 14 of the Act, invoked by the landholder, provides:

SEC. 14. Change of System.—The tenant shall have the right to change the tenancy contract from one of share tenancy to the leasehold tenancy and vice versa and from one crop-sharing arrangement to another of the share tenancy. If the share tenancy contract is in writing and is duly registered, the right may be exercised at the expiration of the period of the contract. In the absence of any written contract, the right may be exercised at the end of the agricultural year. In both cases, the change to the leasehold system shall be effective one agricultural year after the tenant has served notice of his intention to change upon the landholder.

The Court held that this provision does not apply where the tenant merely enforces the sharing that the law already fixes according to actual contributions.

Section 34 of the Act provides:

SEC. 34. Reimbursement Not Allowed.—Contributions or shares in the contribution to the production of the crop in the form of cash, grain or services, once shouldered or rendered alone by one party may not be reimbursed by the other party after the phase or phases of work required in the joint undertaking shall have been completed.

This provision supports the rule that the sharing must follow the contributions actually made, which cannot be undone after the work is done.

Section 56 of the Act provides:

In the interpretation and enforcement of this Act and other laws as well as the stipulations between the landholder and the tenant, the courts and administrative officials shall solve the doubts in favor of the tenant.

This provision guided the Court in resolving the classification question in favor of the tenant.

Ruling

On the first issue, the Court ruled that for purposes of classification, the production of each separate landholding must be taken into account. The share basis in the law is fixed "on ricelands," not on the person tilling. One tenant may therefore hold several areas falling under one or both classifications, and may have separate sharing agreements for each. The Court noted that the two lands were 300 meters apart, that their harvests were stacked separately, and that their produce was separately threshed. San Bartolome yielded a normal average of about 37 cavanes per hectare, making it second class under Section 33. Sto. Tomas yielded about 54 cavanes per hectare, making it first class under Section 32. Doubts were resolved in favor of the tenant under Section 56.

On the second issue, the Court held that Section 14 does not apply. The tenant did not seek a change from one crop-sharing arrangement to another. The contributions of the parties were fixed, and the law itself fixes the corresponding shares. All that was done was to enforce the crop ratio in accordance with actual contributions. The Court quoted its earlier ruling in Pineda versus Pingul:

If any change is desirable in the matter of the sharing ratio, the initiative and decision should lie with the tenant who, under the spirit of the law, must be left to choose and determine what arrangement is suitable and advantageous to him, considering his ability to supply the implements and work animals and to defray the expenses of planting and cultivation.

On the third issue, the Court held that the landholder's disclaimer could not prevail. In her answer, she admitted the tenant's allegation that he had been her tenant since 1942. That judicial admission was conclusive. Her own testimony showed that her aunt managed the farms only on her behalf. She could not escape reliquidation on the plea that the action should be directed against her aunt.

Doctrine

First, the classification of ricelands for tenancy sharing is determined by the production of each separate landholding, not by the total area held by one tenant. A tenant may hold lands of different classes and have a different sharing ratio for each, under Sections 32 and 33 of the Agricultural Tenancy Act.

Second, where the tenant does not seek a change of contract but merely asks that the sharing be fixed according to the contributions actually made, Section 14 of the Agricultural Tenancy Act does not apply. The law itself fixes the shares, and the tenant cannot be made to receive less than the share corresponding to his contributions.

Third, a judicial admission in the answer is conclusive on the party making it. A landholder who admits the tenancy relationship cannot later deny it to escape liability for reliquidation.

Fourth, doubts in the interpretation and enforcement of the Agricultural Tenancy Act are resolved in favor of the tenant under Section 56.

Disposition

The Supreme Court affirmed the judgment of the Court of Agrarian Relations, with costs against the landholder, Trinidad Yaptangco Vda. de Tizon.

Remember This

The one line to memorize: classification of ricelands is per landholding, not per tenant, and the sharing ratio follows actual contributions, not a change of contract under Section 14. Examiners use this case to test the distinction between first and second class land under Sections 32 and 33, and the rule that doubts in tenancy law are resolved in favor of the tenant.