Title
Amante vs. Court of Agrarian Relations
Case
G.R. No. L-21283
Decision Date
Oct 22, 1966
Landowner forcibly ousted tenant despite compromise agreement; court ruled ouster unlawful, reinstated tenant, citing agrarian laws requiring court approval for dispossession.
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Case Digest (G.R. No. L-21283)

Facts:

    Background of the Parties

    • Petitioner Adriano Amante is the owner of a small tract of land in San Isidro, Buhi, Camarines Sur.
    • Respondent Sergio Pama was cultivating the land as a tenant.

    The Agrarian Dispute

    • On June 6, 1962, respondent Pama filed a petition before the Sixth Regional District of the Court of Agrarian Relations in Naga City.
    • The petition sought:
- Reliquidation of the harvest from June 1956 to April 1960. - Reinstatement as a tenant. - Payment of damages. - Failure to receive his rightful share as tenant. - Allegation that petitioner Amante, along with his wife and assisted by Senador Amante, forcibly ousted Pama from the land.

    Petitioner’s Defense and Counterclaims

    • In his answer, petitioner Amante asserted that a compromise agreement was reached on December 14, 1960.
    • Under the compromise:
- Petitioner was to take possession of the property after one (1) year from June 1961, unless he proved his inability to personally cultivate it.

    Procedural History and Scheduling Issues

    • An order dated July 3, 1962, set the hearing for September 18, 1962, in Buhi, Camarines Sur.
    • The day before the hearing, petitioner’s counsel filed a motion for postponement citing:
- A scheduling conflict given his prior commitment on September 17, 1962, to a land registration case in Naga City. - Neither petitioner Amante nor his counsel appeared. - Respondent Pama, along with his counsel, was present and objected to the motion for postponement, which had already been denied by the lower court.

    Subsequent Motions and Lower Court Decisions

    • Petitioner filed multiple motions:
- On October 12, a motion for reconsideration of the order denying the postponement was filed; it was denied on October 24. - A second motion for reconsideration filed on November 18 was similarly denied on December 10. - Directing the reinstatement of respondent Pama as tenant. - Denying the petition for reliquidation of the harvest and damages due to insufficient evidence.

Issue:

    Procedural Issues

    • Whether petitioner’s failure to engage counsel in a timely manner, resulting in his nonappearance at the crucial hearing, constituted sufficient cause for the denial of his motion for postponement.
    • Whether the lower court’s denial of motions for reconsideration, including those pertaining to the postponement and the approval of the compromise agreement, was proper and within its sound discretion.

    Merits of the Case and the Compromise Agreement

    • Whether the compromise agreement, dated December 14, 1960 – which the petitioner relied upon – could be given effect despite being:
- Submitted for approval over six (6) months after the forcible ejectment of respondent Pama. - Denied approval by the Court of Agrarian Relations.

    Tenant’s Rights and Landlord’s Actions

    • Whether the forcible ejectment of respondent Pama by petitioner Amante (with assistance) was legally justified, especially in light of:
- The requirement that a landlord must secure judicial authorization for dispossession when a tenant does not voluntarily abandon the land.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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