Pineda Vs.

De Guzman 21 SCRA 1450 (1967)

FACTS:
Private respondent Beatriz de Feliciano filed against petitioners Francisco Pineda and others, who were
agricultural tenants of private respondent, two cases of ejectment with the Court of Agrarian Relations
(CAR), citing her intention to mechanize her landholdings.

The CAR rendered its decision in favor of private respondent and held that the decision was final and
executory in March, 1964, with private respondent filing a motion of execution on 03 September of the
same year.

Petitioners opposed the motion for execution on 26 September 1964, citing that they had already
cultivated the land in the time after the decision had been rendered, with the crops ready to harvest in the
later months in the year and also in January 1965. They also assert that they were unwilling to be resettled
and that, pursuant to R.A. 1199, as amended, the execution of the CAR’s decision be held in abeyance
until the lapse of one year from date of decision becomes final.

An order was issued granting the execution of the decision, for which a motion of reconsideration of the
order was filed. Said motion of reconsideration was denied, hence this instant petition.

ISSUE:
W/N Petitioners were unjustly dispossessed of the lands on which they were tenants?

RULING:
YES. The law has prescribed that the provision of Section 50(a) of Act 1199, as amended, should be
followed in the adjudication and enforcement of the rights of the parties, and, therefore, the dispossession
of the tenant, who is not willing to be resettled, as the herein petitioners have so stated, "shall not be
enforced until the lapse of one year from the date of the decision becomes final."

The adverted provision of the law contemplates giving to the tenants a protection from a sudden change
of condition of livelihood, and it is a reasonable exercise by the State of its police power to regulate and
control the relationship between landholders and tenants, in compliance with the principle of social justice
embodied in the Constitution.

An aspect of the case which calls for the application of the equity rule is manifested from the fact clearly
established in the record that the petitioner-landholder has been guilty of laches: by allowing the
petitioners to cultivate the land in the rainy-season months following the date when the decision became
final and executory but then only filing for the execution of that decision to dispossess the tenants in
September, near the time of harvest of some of the crops planted. Such an action of the landholder to take
possession of the land from the tenants, at such a time is, to all intents and purposes, an attempt to enrich
herself to the prejudice of the tenants.

HELD:
Section 49 of the Agricultural Tenancy Act, Republic Act 1199, as amended, enunciates the principle of
security of tenure of the tenant, such that it prescribes that the relationship of landholder and tenant can
only be terminated for causes provided by law. The law simply provides that the tenancy relationship
between the landholder and his tenant should be preserved in order to insure the well- being of the tenant
and protect him from being unjustly dispossessed of the land. Its termination can take place only for
causes and reasons provided in the law.