Title
Belleza vs. Dimson Farms, Inc.
Case
G.R. No. L-33355
Decision Date
Apr 11, 1972
Petitioners sought to nullify a preliminary injunction restraining the execution of a CAR decision ordering their reinstatement to disputed lands. The Supreme Court ruled the Court of First Instance lacked jurisdiction, deemed the CAR decision unenforceable due to unclear land descriptions, and allowed reopening to clarify boundaries.
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Case Digest (G.R. No. L-33355)

Facts:

  1. Parties Involved:

    • Petitioners: Francisco Belleza, Lauro Botones, Anatalio Botones, Exequiel Muli, Maximino Cruz, Felipe Pamintuan, Rafael Macaspac, Gregorio Muli, Francisco Cruz, Roberto Bacani, Aurelio Cruz, Ricardo Datu, Juan Garcia, Leonardo Lalic, Armando Lalic, Emilio Dampil, Maximo Belleza, Nicolas Datu, Juan Aquino, and Gregorio Agustoza.
    • Respondents: Dimson Farms, Inc. and Judge Andres C. Aguilar, Presiding Judge of the Court of First Instance, 5th Judicial District, 2nd Branch.
  2. Background of the Case:

    • The petitioners filed a petition for certiorari to nullify a preliminary injunction issued by Judge Andres C. Aguilar on March 9, 1971, in Civil Case No. G-37. This injunction restrained the execution of a joint decision by the Court of Agrarian Relations (CAR) in C.A.R. Case Nos. 1235-P'62, 1236-P'62, and 1251-P'63, which ordered the reinstatement of the petitioners to their landholdings.
  3. Key Events:

    • The CAR had ruled that the petitioners were illegally dispossessed of their landholdings by Rufino Dimson and ordered their reinstatement. However, the decision did not clearly describe the specific lands to which the petitioners were to be reinstated.
    • Dimson Farms, Inc., the respondent, argued that it was not the successor-in-interest of Rufino Dimson and that the lands in question did not belong to Rufino Dimson but to Dimson Farms, Inc.
    • The main issue arose from the lack of clarity in the CAR decision regarding the identification of the lands, leading to disputes over the implementation of the writ of execution.
  4. Agreement Between Parties:

    • During the hearing, both parties agreed that the CAR decision was incomplete due to the lack of a clear description of the lands. They proposed that the CAR reopen the case to delineate the boundaries of the lands in question and render a new decision.

Issue:

  1. Jurisdiction of the Court of First Instance:

    • Whether the Court of First Instance had jurisdiction to issue a preliminary injunction restraining the execution of a final judgment by the Court of Agrarian Relations.
  2. Enforceability of the CAR Decision:

    • Whether the CAR decision could be enforced given the lack of a clear description of the lands to which the petitioners were to be reinstated.
  3. Successor-in-Interest:

    • Whether Dimson Farms, Inc. was the successor-in-interest of Rufino Dimson and whether the lands in question belonged to Rufino Dimson or Dimson Farms, Inc.

Ruling:

  1. Jurisdiction:

    • The Supreme Court ruled that the Court of First Instance acted without jurisdiction in issuing the preliminary injunction. The Court of Agrarian Relations, being a court of special jurisdiction, has exclusive authority over agrarian disputes, and its final judgments cannot be enjoined by a Court of First Instance.
  2. Enforceability of the CAR Decision:

    • The Supreme Court held that the CAR decision was unenforceable as it stood because it lacked a clear description of the lands. However, the Court allowed the CAR to reopen the case for the sole purpose of delineating the boundaries of the lands and rendering a new decision.
  3. Successor-in-Interest:

    • The Court did not directly address the issue of whether Dimson Farms, Inc. was the successor-in-interest of Rufino Dimson, as the parties agreed to resolve the matter by clarifying the land descriptions in the CAR.

Ratio:

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