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VILLAVIZA vs.

PANGANIBAN
G.R. No. L19760
30 APRIL 1964

MARCELO VILLAVIZA, et. al., vs. JUDGE TOMAS PANGANIBAN, et. al.

Review of a Court of Agrarian Relations decision.


Justice J. B. L. Reyes

FACTS:
Petitioner Villaviza et. al. were tenants in a riceland (Aliaga, Nueva Ecija) owned by Domingo Fajardo since 1944.
By 1955 Fajardo leased the land to a Quirino Capalad, who cultivated the land through the use of machinery and
also by hiring other tenants.
When petitioners went back to their specific landholdings to prepare them for planting, they found that the land
was already cultivated. They demanded Capalad to reinstate them as farmer-tenants.
However, Capalad failed to reinstate them despite making promises to do so. Petitioners then filed a suit with
the Court of Agrarian Reform against Capalad.
CAR Ruling: Petitioners should vacate the property and for Capalad to pay them for indemnity. Hence, this
petition.

ISSUE: Whether or not the CAR committed grave abuse of discretion.


HELD: NO.

RATIO:
The Supreme Court found no grave abuse of discretion by the Agrarian Court; and held that the decision of the
lower court is supported by substantive evidence based on the testimonies of witnesses and which were not
questioned by petitioners.

A tenants right to be respected in his tenure under RA 1199, as amended, is an obligation of the landholder
created by law, and an action for violation thereof prescribes in 10 years.
o In the case at bar, the petitioners were ousted from the landholdings in June 1955 and filed their
complaint on 31 March 1960; thus, their filing of an action had not yet expired. However, the lower
court found that petitioners have engaged in gainful occupations since their illegal ejectment and had
delayed the filing of the case, and for this reason the lower court awarded damages equivalent to only 2
harvests based on the landholders share for the crop year.

The SC held that under Sec. 27 (1) of RA 1199, a tenants earnings may not be deducted from damages because
the said section positively provides that the tenants freedom to earn elsewhere is to be added to his right to
damages in case of illegal ejectment. Also, petitioners are not guilty of laches since the delay in instituting the
action was due to the promises Capalad made. However, the SC did not modify the award of damages because
of the lack of appeal from the decision indicates their satisfaction therewith and a waiver of any amounts other
than those indicated in the decision.