BERNARDO PICARDAL AND SEBASTIAN PICARDAL, PETITIONERS, VS. CENON LLADAS, RESPONDENT.

Picardal versus Lladas

The Case

This is a petition for review brought by Bernardo Picardal and his son Sebastian Picardal against their former coconut tenant, Cenon Lladas. The Picardals ask the Supreme Court to overturn a decision of the Court of Agrarian Relations which found that they had unlawfully ejected Lladas from the landholding and ordered his reinstatement and the payment of damages. The case matters for two reasons. First, it fixes the standard by which the Supreme Court reviews the factual findings of the Court of Agrarian Relations, namely substantial evidence. Second, and more importantly for the bar, it draws a sharp line between the liability of the tenant's landlord and the liability of the individual who actually carries out the unlawful dispossession, a distinction that becomes critical when the land is under judicial administration as part of an estate.

Procedural History

The case began in the Court of Agrarian Relations, where Cenon Lladas filed a petition against Bernardo Picardal and others, later amended twice to substitute parties, including the special administrator and later the administratrix of the estate. After trial, the Court of Agrarian Relations rendered its decision in December 1962. It ordered the reinstatement of Lladas to the landholding, ordered Bernardo Picardal and Sebastian Picardal to pay jointly and severally the sum of four thousand five hundred fifteen pesos in damages with interest, and ordered them to pay six hundred forty five pesos every four months from January 1963 for as long as Lladas was not actually reinstated, plus the costs. The Picardals moved for reconsideration, which was denied. They then appealed directly to the Supreme Court by petition for review.

Facts

Sometime in 1950, Bernardo Picardal entrusted to Cenon Lladas a parcel of about seven hectares planted to some eight hundred twelve fruit bearing coconut trees in Linamon, Lanao del Norte. The land formed part of the conjugal partnership of Bernardo and his wife Aurea Burgos, who died in 1941, and it was under judicial administration in the settlement proceedings of her estate, not yet partitioned among the heirs. By verbal agreement, the coconut produce would be divided one third to the landowner and two thirds to the tenant, and Lladas would keep the plantation clean. Lladas entered, harvested, processed the nuts into copra, sold the produce, and divided the proceeds as agreed.

In November 1959, the Clerk of Court, as special administrator, wrote to Lladas advising him to take good care of the plantation. In February 1960, Lladas harvested and processed copra, which Bernardo Picardal sold to a company in Iligan City. The buyer complained that the copra had been mixed with fresh coconut meat, causing a sixteen percent deduction for moisture, and asked Picardal to advise Lladas to stop the practice. In March 1960, Lladas filed his petition in the Court of Agrarian Relations, alleging that he had been served a notice to vacate half of the landholding so it could be given to another tenant. The Picardals denied any notice of ejectment and claimed the land was under judicial administration.

In May 1960, Lladas again harvested and processed copra, which Bernardo Picardal sold, delivering to Lladas his share of six hundred forty five pesos. Lladas made no further harvests after May 1960, although his house remained on the land and he continued to raise short term crops. In October 1960, he amended his petition to allege that Sebastian Picardal, with the knowledge and consent of Bernardo Picardal, had ejected him in September 1960, and that he had planted banana hills and fruit trees whose produce he shared equally with Bernardo. The Picardals denied the ejectment and claimed Lladas had abandoned the landholding.

Issues

• Whether or not the finding of the Court of Agrarian Relations that Cenon Lladas was ejected from the landholding is supported by substantial evidence.
• Whether or not the damages awarded should be levied against the intestate estate of Aurea Burgos rather than against the petitioners personally.

Applicable Provisions

Section 27, paragraph 1 of Republic Act Numbered Eleven Hundred Ninety Nine, the Agricultural Tenancy Act, provides:

The landlord is liable when he is responsible for the unlawful ejectment; otherwise, he is not.

This fixes the landlord's liability for dispossessing a tenant upon the landlord's own responsibility for the act.

Section 49 of the same Act provides:

Section 49 of the same Act renders the third party himself who unlawfully dispossesses a tenant, liable for damages.

This makes the actual wrongdoer, even one who is not the landlord, answerable for the damages.

Article 18 of the Civil Code provides:

Every person who, contrary to law, willfully or negligently causes damage to another, shall indemnify the latter for the same.

This is the general basis for holding the petitioners personally liable for their unlawful act.

Article 1078 of the Civil Code provides:

The intestate estate before partition is owned in common by all the heirs.

This supports the ruling that the estate, as a co-ownership, should not suffer for the act of only two of the heirs.

Article 501 of the Civil Code provides:

A co-ownership should not suffer the consequences of the unlawful act of any of the co-owners.

This reinforces the same conclusion.

Ruling

On the first issue, the Court held that the finding of the Court of Agrarian Relations was supported by substantial evidence and would not be disturbed. Substantial evidence means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion, and it does not require preponderant evidence. The absence of substantial evidence is not shown merely by stressing contrary evidence on record, and the appellate court cannot substitute its own judgment for that of the trial court on the weight of evidence. The lower court had weighed both sides and given its reasons, finding that the Picardals had a more compelling motive to oust the tenant than the tenant had to abandon a holding yielding him more than six hundred pesos every four months.

On the second issue, the Court agreed that the entire conjugal property was under administration, so that the estate was really the landlord. But this did not shift liability to the estate. The Court reasoned that the Tenancy Act does not hold the landlord liable under all circumstances, but only when the dispossession is imputable to him, while the third party who unlawfully dispossesses a tenant is himself liable. Since it was Bernardo and Sebastian Picardal who ejected Lladas, they must bear the consequences. The Court gave four reasons why the estate could not be made liable: the petitioners did not represent the estate, whose representative was the special administrator; the estate did not benefit from the dispossession, since it would have received its two thirds share either way; the estate before partition is a co-ownership that should not suffer for the act of only two heirs; and under Article 18 of the Civil Code the petitioners themselves must indemnify the respondent.

Doctrine

First, the factual findings of the Court of Agrarian Relations will not be disturbed on appeal where supported by substantial evidence, meaning such relevant evidence as a reasonable mind might accept as adequate to support a conclusion, which does not require preponderant evidence. Second, under the Agricultural Tenancy Act, the landlord is liable for damages for dispossessing a tenant only when the dispossession is imputable to him; the third party who himself unlawfully dispossesses the tenant is personally liable. Third, liability for unlawful ejectment cannot be shifted to an intestate estate where the wrongdoers did not act for the estate, the estate did not benefit, and the estate before partition is a co-ownership that should not suffer for the unlawful act of some of the heirs.

Disposition

The Supreme Court affirmed the decision of the Court of Agrarian Relations in full, with costs against the petitioners, so that Cenon Lladas won reinstatement and damages against Bernardo and Sebastian Picardal personally.

Remember This

The one line to memorize is that it is the landlord who is responsible for the unlawful ejectment, and the third party who actually dispossesses the tenant, who are liable for damages, never the innocent estate. Examiners use this case to test the substantial evidence standard for agrarian findings and the rule that liability for unlawful dispossession follows the actual wrongdoer and cannot be passed to a co-owned estate.