Case Digest (G.R. No. L-48547)
Facts:
Alfonso Angliongto, Jr. v. The Honorable Court of Appeals, Jesus Geverola, Jose Geverola, Felisa Geverola, and Marcelo Capuno, G.R. No. L-48547, September 21, 1982, Supreme Court Second Division, Barredo, J., writing for the Court. Petitioner Alfondo Angliongto, Jr. sought review of the Court of Appeals decision in CA-G.R. No. SP-07099 that had reversed the Court of Agrarian Relations of Davao City.The original owner of the 32-hectare coconut land was Bernardo Geverola. After Bernardo’s death his estate was settled in Special Proceedings No. 4 (Court of First Instance of Davao del Sur), which adjudicated Isidoro Geverola as sole heir. Isidoro later died; his estate was administered in Special Proceedings No. 55 (Court of First Instance of Davao City) at the instance of petitioner, who was also the principal creditor (a mortgagee) holding a claim of over P45,000 secured by mortgage on the disputed property.
When the indebtedness remained unpaid, the mortgage on the property was foreclosed and petitioner, acting as administrator of the estate, was the sole bidder and purchaser at auction for the amount of the indebtedness. Several persons, including Jesus Geverola, Jose Geverola, Felisa Geverola and Marcelo Capuno (through his wife Luisa, a Geverola), claimed they were agricultural tenants of the prior owners and therefore entitled to preemption rights under the Agricultural Tenancy Act, Republic Act No. 1199 (RA 1199), Section 6.
The Court of Agrarian Relations (trial agrarian court) conducted a commission’s inspection and received reports of coconut plantings allegedly occupied by the respondents, but found that the respondents were not agricultural tenants. Instead the trial court concluded they were fostered grandnephews and grandnieces whom Bernardo had reared and assigned portions of land to work as close kin and household helpers — a familial arrangement that terminated on Bernardo’s death — and ordered them to surrender possession to petitioner.
The Court of Appeals reversed, holding that the respondents’ cultivation and 75%-25% sharing arrangements with the deceased landowner met the definition of tenancy under Sec. 6, RA 1199, and thus they had rights as agricultural tenants. Petitioner brought...(Pro-only)
Issues:
- Whether the private respondents were agricultural tenants of the landowner within the meaning of Section 6 of Republic Act No. 1199.
- If they were agricultural tenants, whether they were entitled to preemption rights against petitioner as purchaser at the mortgag...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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