Facts:

The case involves a petition for certiorari with preliminary injunction filed by Calixto Angel (petitioner) against Hon. Ponciano C. Inopiquez, the Presiding Judge of the Regional Trial Court (RTC) of Nueva Vizcaya, Branch XXX, and Martin Pimentel (respondents). The events leading to the case began with a leasehold contract dated September 1979 between the petitioner and the private respondent concerning two parcels of land in San Luis, Nueva Vizcaya, with an agreed rental of fifty-five (55) cavans of palay per cropping season. Prior to this leasehold arrangement, their relationship was characterized by a share tenancy with a 50-50 sharing basis. The private respondent failed to cultivate the land, prompting the petitioner to file a complaint for declaration of abandonment against the private respondent on September 25, 1981, before the Court of Agrarian Relations, which was later dismissed upon the petitioner's verbal motion to withdraw the complaint on July 15, 1982.

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Facts:

Background of the Case

• Calixto Angel is the petitioner and owner of two parcels of land in San Luis, Nueva Vizcaya.
• The land was initially subject to a share tenancy arrangement on a 50-50 basis before being converted to a leasehold contract with an agreed rental of fifty-five (55) cavans of palay per cropping season.

Initiation of Agrarian Actions

• On September 25, 1981, petitioner filed a complaint for declaration of abandonment against the private respondent before the Court of Agrarian Relations, Branch IV, Bayombong (CAR Case No. 1230-NV 81), later amended.
• Petitioner verbally moved for withdrawal of his amended complaint on July 15, 1982, with private respondent not objecting, leading to the eventual dismissal of the case.

Filing of the Reinstatement Case

• On August 3, 1982, private respondent initiated a separate proceeding by filing a Reinstatement with Damages case (renumbered as RTC Civil Case No. 26).
• The private respondent alleged that petitioner, with assistance, had surreptitiously plowed, harrowed, and planted palay on the land, and upon private respondent’s objection, petitioner warned him not to enter the premises.

Judgment Rendered by the Lower Court

• After trial, on November 28, 1983, respondent Judge rendered a decision with the following key orders:
• The immediate reinstatement of the private respondent to the landholding.
• The directive for petitioner or his agent to vacate the premises.
• Payment of 330 cavans of palay per calendar year until peaceful possession is restored.
• Payment of P20,000.00 as exemplary damages and P2,000.00 as attorney’s fees.
• Declaration that the tenant had paid an indebtedness of P13,000.00 to the petitioner.
• Costs ordered against the petitioner.
• On December 19, 1983, petitioner filed a Notice of Appeal from the adverse decision.
• On December 20, 1983, the respondent Judge approved the appeal and directed the case records to be transmitted to the Intermediate Appellate Court (now Court of Appeals).

Subsequent Motions and Execution Pending Appeal

• On January 10, 1984, private respondent filed a Motion for Execution Pending Appeal.
• On January 16, 1984, the respondent Judge granted the motion, directing the issuance of a partial writ of execution enforcing only the orders regarding reinstatement and vacating of the premises.
• On February 3, 1984, petitioner filed a Motion for Reconsideration, arguing that the respondent Judge lacked jurisdiction because the appeal had already been perfected and records transmitted to the appellate level.
• The respondent Judge denied the Motion for Reconsideration on February 22, 1984.

Certiorari Petition and Further Appellate Proceedings

• Petitioner filed a petition for Certiorari with Preliminary Injunction on March 21, 1984 challenging the January 16, 1984 order and the February 22, 1984 denial of reconsideration.
• The petition was given due course in the resolution rendered on January 30, 1985.
• On June 29, 1984, the Intermediate Appellate Court (now Court of Appeals) rendered a decision on petitioner’s appeal with modifications, notably deleting the award of exemplary damages and attorney’s fees.
• On September 3, 1984, petitioner filed a petition for Review on Certiorari before the Supreme Court seeking reversal of the Intermediate Appellate Court’s decision.
• On September 12, 1984, the Supreme Court resolved to deny the petition for Review on Certiorari, citing lateness and lack of merit; the resolution became final and executory on October 12, 1984.

Procedural and Legal Framework Considerations

• Petitioner contended that the perfection of the appeal and the transmission of the records rendered the lower court’s issuance of the partial writ of execution improper.
• The case is an agrarian/tenancy dispute and, as such, is governed not by the standard Rules of Court but by special procedures under Presidential Decree No. 946 and Batas Pambansa Blg. 129.
• The provisions of PD 946, particularly Sections 16 and 18, emphasize that the Rules of Court do not apply to agrarian cases and that an appeal does not stay the decision except in ejectment cases.
• Past jurisprudence cited (e.g., Munoz v. Bagasao, Calasiao Farmers Cooperative Marketing Association v. C.A.) underscores that a final decision on the merits renders procedural challenges moot and academic.

Issue:

• Whether the issuance of a Writ of Execution Pending Appeal by the trial court after the perfection of the appeal is proper in agrarian cases, given the special procedural rules under PD 946.
• Whether the trial court retained jurisdiction to issue such writ notwithstanding the perfection of the appeal, considering that agrarian cases are not governed by the general Rules of Court but by special rules intended to secure expeditious and just resolutions.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)