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Guerrero vs CA


In 1969, Apolinario Benitez was taken by Sps. Guerrero to take care of their 60 heads of
cows which were grazing within their 21-hectare coconut plantation. Plaintiff was allowed to put
up a hut within the plantation where he and his family stayed. In addition to attending to the
cows, he was made to clean the already fruit bearing coconut trees, burn dried leaves and grass
and to do such other similar chores. During harvest time, he was also made to pick coconuts
and gather the fallen ones from a 16-hectare portion of the 21-hectare plantation. He had to
husk and split the nuts and then process its meat into copra in defendants' copra kiln. For his
work related to the coconuts, he shared 1/3 of the proceeds from the copra he processed and
sold in the market. For attending to the cows he was paid P500 a year. In1973, Benitez was
refrained from gathering nuts from the 10-hectare portion of the 16-hectare part of the plantation
from where he used to gather nuts. He felt aggrieved by the acts of Sps. Guerrero and he
brought the matter to the attention of the Office of Special Unit in the Office of the President in
Malacanang, Manila. This led to an execution of an agreement, whereby Sps. Guerrero agreed,
among others, to let Benitez work on the 16-hectare portion of the plantation as tenant thereon
and that their relationship will be guided by the provisions of RA No. 1199 or The Agricultural
Tenancy Act of the Philippines. In July, 1973, he was again refrained from gathering nuts from
the 10-hectare portion of the plantation with threats of bodily harm if he persists to gather the
fruits. Sps. Guerrero, then assigned Rogelio and Paulino Latigay to do the gathering of the nuts
and the processing thereof into copra. Sps. Guerrero also caused to be demolished a part of the
cottage where Benitez and his family lived. Hence, this case for reinstatement with damages.

Whether or not a tenancy relationship exists between the parties Manuel Guerrero, et al
and Apolinario Benitez, et al.?

Yes. Sps. Guerrero to reinstate Benitez to the 10-hectare portion of the 16-hectare
coconut holding in question and to maintain Benitez in the peaceful possession and cultivation
thereof, with all the rights accorded and obligations imposed upon him by law.
The Agricultural Tenancy Act of 1954 (Republic Act 1199), the Agricultural Land Reform
Code of 1963 (Republic Act 3844), the Code of Agrarian Reforms (Republic Act 6389) and
Presidential Decree 1038 (Strengthening the Security of Tenure of Tenant Tillers in Non-Rice/
Corn Producing Agricultural Lands) all provide for the security of tenure of agricultural tenants.
Ejectment may be effected only for causes provided by law, to wit:
l) Violation or failure of the tenant to comply with any of the terms and conditions of the tenancy
contract or any of the provisions of the Agricultural Tenancy Act;
2) The tenant's failure to pay the agreed rental or to deliver the landholder's share unless the
tenant's failure is caused by a fortuitous event or force majeure;
3) Use by the tenant of the land for purposes other than that specified by the agreement of the
4) Failure of the tenant to follow proven farm practices:
5) Serious injury to the land caused by the negligence of the tenant;
6) 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. (Section 50,
Rep. Act 1199).
None of the above causes exists in the case at bar. The respondent has been unlawfully
deprived of his right to security of tenure and the Court of Agrarian Reforms did not err in
ordering the reinstatement of respondent as tenant and granting him damages therefor.