Case Digest (G.R. No. L-21281)
Facts:
- Case of Balane v. De Guzman
- Petition for mandamus filed by a group of tenants
- Respondents: Francisco Quintela, Oliva Bustos, Jesus Ma. Bernarte, and Pastor L. De Guzman (presiding judge)
- Filed on September 20, 1962, in Naga City, Philippines
- Francisco Quintela unlawfully ejected from a landholding in Paracale, Camarines Norte, owned by Oliva Bustos
- Quintela seeks reinstatement and compensation for improvements made on the land
- Oliva Bustos and Jesus Ma. Bernarte deny the allegations
- Petitioners (Edilberto Balane and others) file a motion for intervention, claiming to be bonafide tenants on the land and the ones who planted the coconut trees claimed by Quintela
Issue:
- (Unlock)
Ruling:
- The court granted the writ of mandamus and ordered the respondent judge to allow the in...(Unlock)
Ratio:
- The court's discretion to allow intervention is not unlimited.
- Factors to consider: undue delay or prejudice to the original parties' rights, and whether the intervenor's rights can be fully protected in a separate proceeding.
- Denial of intervention may be arbitrary or capricious if it violates due process and if an ordinary appeal is not an adequate and speedy remedy.
- In this case, the intervention would not unduly delay the case as the motion was filed before trial.
- The petitioners' rights would not be fully protected in a separate proceeding.
- Ruling in favor of Quintela without allowing th...continue reading
Case Digest (G.R. No. L-21281)
Facts:
In the case of Balane v. De Guzman, a group of tenants, namely Edilberto Balane, Gaspar Francisco, Pio Magdamit, Pablo Valeros, Felix Elnar, Armando Galero, Jovito Palma, Modesto Salen, Alberto Valeros, and Luciano Valeros, filed a petition for mandamus to intervene in a land dispute case. The case was filed with the Court of Agrarian Relations, 6th Regional District, Naga City, and was docketed as CAR Case No. 197-CN '62. The respondent in the case was Francisco Quintela, who alleged that he was the tenant-overseer of the lands belonging to Oliva Bustos in the Municipality of Paracale, Camarines Norte. Quintela claimed that he was unlawfully ejected from the landholding and sought reinstatement and compensation for the improvements he made. Oliva Bustos and Jesus Ma. Bernarte, the landowners, filed their answer denying the allegations. The petitioners filed a motion for intervention, asserting that they were the only bonafide tenants on the land and that they were the ones who planted the coconut trees claimed by Quintela. They requested the dismissal of Quintela's petition and asked for attorney's fees. H...