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1 Villaviza vs. Panganiban - Orense

This case digest summarizes a 1964 Supreme Court case involving tenants who were ejected from their riceland holdings in 1955. The Court of Agrarian Relations ruled against reinstating the tenants. The Supreme Court upheld this decision, finding that while the tenants' action was not barred by the statute of limitations, they were guilty of laches for unnecessarily delaying the filing of the case for five years based on unfulfilled promises of reinstatement. The Supreme Court also established that a tenant's right to security of tenure creates an obligation on landholders under agrarian law, and actions for violations of this right prescribe within ten years.

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394 views1 page

1 Villaviza vs. Panganiban - Orense

This case digest summarizes a 1964 Supreme Court case involving tenants who were ejected from their riceland holdings in 1955. The Court of Agrarian Relations ruled against reinstating the tenants. The Supreme Court upheld this decision, finding that while the tenants' action was not barred by the statute of limitations, they were guilty of laches for unnecessarily delaying the filing of the case for five years based on unfulfilled promises of reinstatement. The Supreme Court also established that a tenant's right to security of tenure creates an obligation on landholders under agrarian law, and actions for violations of this right prescribe within ten years.

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Ab Castil
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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CASE

DIGEST
Written By: Ma. Lorna I. Orense

MARCELO VILLAVIZA, ET AL., petitioners, vs. JUDGE TOMAS PANGANIBAN, ET AL.,
respondents (No. L-19760, April 30, 1964)

Doctrine: Prescription of action for violation of security of tenure of tenant A tenants
right to be respected in his tenure under Republic Act 1199, as amended, is an obligation of the
landholder created by law, and an action for violation thereof prescribes in ten years under No.
2 of Article 1144 of the Civil Code.

Facts: Domingo Fajardo, as owner of a riceland in Aliaga, Nueva Ecija, gave out the land for
lease to one Quirino Capalad starting the crop year 1955-1956. However, it is found out that
herein petitioners were already tenants of the said riceland since 1944.

In June 1955, Capalad installed and plowed the land by machinery. The petitioners were
demanding for their reinstatement but to no avail. This prayer was filed with the Court of
Agrarian Relations (CAR). The CAR ruled against herein petitioners and ordered the latter to
vacate their respective landholdings, hence, the instant petition for review.

Issue: Whether or not CAR committed grave abuse of discretion

Ruling: NO.

The Court believed the evidence for the respondents, rather than those for the petitioners since
the decision of CAR contains the recitals of the testimonies of the witnesses and the petitioners
did not question its existence and adequacy. As such, the Court will not weigh anew the
evidence presented herein.

A tenants right to be respected in his tenure under Republic Act 1199, as amended, is an
obligation of the landholder created by law and an action for violation hereof prescribes in ten
years under No. 2 of Article 1144 of the Civil Code. The petitioners were ousted from their
landholdings in June 1955 and they filed the present action on March 31, 1960; therefore, the
period of limitation had not expired. However, the tenancy court found that the petitioners have
engaged in gainful occupations since their illegal ejectment and had delayed the filing of the
case. They were found guilty of laches for having unnecessarily delayed the filing of the case,
because the delay was attributed to Capalads promises to reinstate them.

The Court affirmed the CARs decision.

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