Issue: How should indemnification to a tenant be computed?

Applicable Laws and Jurisprudence:

1.) Article 443, NCC

He who receives the fruits has the obligation to pay the expenses made by a third
person in
their production, gathering, and preservation.
2.) Section 25, RA 3844
Right to be Indemnified for Labor - The agricultural lessee shall have the right
to be indemnified for the cost and expenses incurred in the cultivation,
planting or harvesting and other expenses incidental to the improvement of
his crop in case he surrenders or abandons his landholding for just cause or
is ejected therefrom. In addition, he has the right to be indemnified for one-half
of the necessary and useful improvements made by him on the landholding:
Provided, That these improvements are tangible and have not yet lost their utility at
the time of surrender and/or abandonment of the landholding, at which time their
value shall be determined for the purpose of the indemnity for improvements.

3.) Section 22 (4), RA 1199

The tenant shall have the right to be indemnified for his labor and
expenses in the cultivation, planting, or harvesting and other incidental
expenses for the improvement of the crop raised in case he is dispossessed of
his holdings, whether such dismissal is for a just cause and not, provided the crop still
exists at the time of the dispossession.
4.) Leon del Rosario vs. Hon. Bienvenido Chingcuangco (G.R. No. L-25503 ;December 17,
1966) citing Section 43, RA 1199
Rights and Obligations of Tenant-LesseeWith the creation of the tenancy
relationship arising out of the contract between the landholder-lessor and tenantlessee, the latter shall have the right to enter the premises of the land, and to the
adequate and peaceful enjoyment thereof. He shall have the right to work the land
according to his best judgment, provided the manner and method of cultivation and
harvest are in accordance with proven farm practices. Upon termination of the
relationship, he shall be entitled to one-half of the value of the
improvements made by him, provided they are reasonable and adequate to
the purposes of the lease.

*Derived formula from the applicable provisions:

Labor
+ Expenses (Cultivation, Planting and Harvesting)
+ Other incidental expenses for the improvement of the crop raised
+ One-half of the value of the improvements made by lessee (provided they are
reasonable and adequate to the purposes of the lease and have not lost their utility at the
time of surrender and/or abandonment of the landholding)
_________________________
= Indemnification entitled to the lessee