Case Digest (G.R. No. L-24458-64)
Facts:
Amando Algabre, et al. v. The Court of Appeals, and Rebecca Andres, G.R. Nos. L-24458-64, July 31, 1969, the Supreme Court En Banc, Barredo, J., writing for the Court. Petitioners are a group of tenant-farmers; respondents are The Court of Appeals and landholder Rebecca Andres.The facts, as found by the Court of Appeals and accepted by the Supreme Court, are these. Rebecca Andres and three groups of tenants executed separate but identical extrajudicial compromise agreements whereby the tenants surrendered certain palay landholdings in favor of Andres; in consideration Andres condoned past and present loans and delivered specified sums of money to the tenants. Each agreement bore an acknowledgment by the signatories before a deputy clerk of court and was submitted to the Court of Agrarian Relations (CAR) for approval. The CAR (Judge Valeriano A. del Valle presiding) approved the agreements and rendered judgments so stating, finding nothing contrary to law, morals or public policy.
Some months later the tenants, through counsel, filed motions for reconsideration alleging coercion, intimidation, trickery in securing signatures, and nonpayment of the agreed amounts. The landholder opposed, asserting finality under Section 12 of Republic Act No. 1267, as amended by RA 1409. In April 1964 Judge Jose R. Cabatuando of the CAR denied one motion for reconsideration as filed out of time but, in an apparently inconsistent July 15, 1964 order, vacated and set aside the judgments in the three compromise-agreement cases on grounds including lack of summons and want of jurisdiction; a motion to reconsider that vacating order was denied. During the interval six tenants filed separate CAR petitions seeking reinstatement to portions of the land vacated under the compromises; the CAR overruled the landholder's motion to dismiss those reinstatement petitions and Commissioner Carmelino L. Ipac proceeded to an ex parte hearing on August 7, 1964, which was later declared null by the Court of Appeals.
The landholder elevated the controversies to the Court of Appeals, which: (a) declared null and void the CAR's July 15, 1964 vacating order and the ex parte hearing; (b) directed the CAR to set for hearing CAR Cases Nos. 2217, 2455 and 2456 to determine (i) whether the judgments approving the compromises had become final and (ii) if not, whether there was sufficient evidence of fraud, violence or nonpayment to annul the judgments; and (c) enjoined the CAR from proceeding with the reinstatement cases until final judgment on ...(Subscriber-Only)
Issues:
- Did the CAR's approval of the extrajudicial compromise agreements, in the absence of a pending case and without formal summons, deprive the tenants of due process or render the CAR without jurisdiction?
- Did the compromise agreements, as signed and partially performed, have the effect of res judicata even if the CAR's approval was irregular, and was the Court of Appeals correct to annul the CAR's vacating order while remanding the matters for determination of vitiated consent?
- How should the CAR proceed as to (a) the allegation of vitiated consent (fraud, coercion, no...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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