April 2012 - Philippine Supreme Court Resolutions
Philippine Supreme Court Resolutions
[G.R. No. 200043 : April 25, 2012]
ALFREDO CASTRO v. BENIGNO FLORES
G.R. No. 200043 (Alfredo Castro v. Benigno Flores).
RESOLUTION
The Court resolves to DENY the petition. A review of the records showed that the Court of Appeals (CA) did not commit a reversible error when it affirmed the DARAB's ruling. The factual findings of the agricultural tribunal are supported by substantial evidence. There appears to be no reason to modify their ruling. The CA does not dispute Alfredo Castro's ownership of the property. They merely upheld the tenancy relationship between him and Benigno Flores. Section 7 of Republic Act (R.A.) 3844 bestows security of tenure once a tenancy relationship is established. As mentioned earlier, Section 37 of the same R.A. requires the agricultural lessor to prove the existence of a lawful cause for the ejectment of an agricultural lessee. While Section 36(6) of R.A. 3844, although permitting ejectment for non-payment of the lease rental, requires that such be intentional. In Sta. Ana v. Carpo,[1] the Court reiterated the longstanding doctrine that "mere failure of a tenant to pay the landholder's share does not necessarily give the latter the right to eject the former when there is lack of deliberate intent on the part of the tenant to pay." Castro did not discharge the burden of proof. Therefore, the tenancy relationship must be respected. Benigno Flores must pay all rentals due to Alfredo Castro. cralaw
SO ORDERED.
Very truly yours,
(Sgd.) LUCITA ABJELINA-SORIANO
Division Clerk of Court
Endnotes:
[1] G.R. No. 164340, November 28, 2008, 572 SCRA 463, 485.