Case Digest (G.R. No. L-21283)
Facts:
The case involves Adriano Amante as the petitioner and the Court of Agrarian Relations, 6th Regional District, along with Sergio Pama as the respondents. The events transpired in San Isidro, Buhi, Camarines Sur, where Amante owned a small tract of land that was cultivated by Pama as a tenant. On June 6, 1962, Pama filed a petition with the Sixth Regional District of the Court of Agrarian Relations in Naga City, seeking a reliquidation of his harvest from June 1956 to April 1960, reinstatement, and damages. Pama claimed he had not received his rightful share as a tenant during that period and alleged that on May 28, 1962, Amante and his wife, with the help of Senador Amante, forcibly ousted him from the land, which was subsequently cultivated by Senador Amante and Dionisio Anapola. In response, Amante contended that a compromise agreement dated December 14, 1960, entitled him to take possession of the property after one year from June 1961, unless he could not personally culti...
Case Digest (G.R. No. L-21283)
Facts:
Ownership and Tenancy
Petitioner Adriano Amante is the owner of a small tract of land in San Isidro, Buhi, Camarines Sur, which was cultivated by respondent Sergio Pama as a tenant.
Petition by Sergio Pama
On June 6, 1962, Pama filed a petition with the Sixth Regional District of the Court of Agrarian Relations in Naga City. He sought reliquidation of the harvest from June 1956 to April 1960, reinstatement, and damages. Pama alleged that he did not receive his rightful share as a tenant during this period and that on May 28, 1962, Amante and his wife, with the assistance of Senador Amante, forcibly ousted him from the land. The land was subsequently cultivated by Senador Amante and Dionisio Anapola.
Answer and Compromise Agreement
In his answer dated June 20, 1962, Amante claimed that a compromise agreement between him and Pama, dated December 14, 1960, entitled him to take possession of the property after one year from June 1961, provided he could not personally cultivate it.
Procedural Events
The case was set for hearing in Buhi, Camarines Sur, on September 18, 1962. On September 17, Amante's counsel filed a motion for postponement, citing his recent engagement and a conflicting hearing in Naga City. The motion was denied, and neither Amante nor his counsel appeared at the hearing. Pama presented his evidence, and the case was submitted for decision.
Subsequent Motions and Denials
Amante filed motions for reconsideration, all of which were denied. He also moved for the approval of the compromise agreement, but this was denied on March 20, 1963.
Lower Court Decision
On March 31, 1963, the lower court ruled in favor of Pama, ordering his reinstatement but denying his claims for reliquidation of the harvest and damages due to insufficient evidence.
Petition for Review
Amante filed a petition for review by certiorari, challenging the lower court's order and decision.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Motions for postponement are within the discretion of the lower court, and appellate courts will not interfere unless there is an abuse of authority.
- A compromise agreement does not automatically extinguish a tenancy relationship, and landlords cannot forcibly dispossess tenants without court approval.
- Under Section 49 of Republic Act No. 1199, as amended, tenants cannot be dispossessed except for authorized causes and only after court approval, even if the tenancy agreement has expired.