Title
Calo vs. Spouses Villanueva
Case
G.R. No. 153756
Decision Date
Jan 30, 2006
Spouses Villanueva claimed tenancy rights over 5 hectares of Calo's land, denied by petitioners. Court of Appeals dismissed on technicalities; Supreme Court remanded for merits-based resolution, emphasizing substantial justice over procedural flaws.
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Case Digest (G.R. No. 153756)

Facts:

Background of the Case

  • On January 2, 2001, respondents Spouses Jacinta and Jose Villanueva filed a case for unlawful ejectment and damages before the Provincial Agrarian Reform Office (PARO) in CARAGA Region XIII, San Francisco, Agusan del Sur, against petitioners Atty. Federico Calo (the alleged landowner) and his son, Norman Calo (the alleged manager of the property).
  • Respondents claimed that since 1966, they had cleared second-growth forests and cultivated crops and coconut trees on a 2-hectare portion of Atty. Calo's property under a share-tenancy agreement (2/3 to the tenant and 1/3 to the owner). They also alleged that in 1979, they were allowed to cultivate an additional 3 hectares under the same terms.

Petitioners' Defense

  • Petitioners denied the tenancy claim, asserting that respondents were merely "piados" or caretakers tasked with preventing squatters from entering the property. They argued that respondents were not entitled to security of tenure under Republic Act (R.A.) No. 6657 (Comprehensive Agrarian Reform Law).

Procedural History

  • After pre-trial and submission of position papers, Regional Adjudicator Jimmy V. Tapangan ruled on June 15, 2001, declaring respondents as lawful tenants-lessees of 5 hectares of land registered in Norman Calo's name. The decision cited Section 34 of R.A. No. 3844 (Agricultural Land Reform Code).
  • Petitioners filed a Motion for Reconsideration on July 12, 2001, requesting an ocular inspection to verify respondents' claims. During the inspection, Danilo R. Calo and Federico R. Calo Jr. (intervenors) claimed ownership of the land and filed a Motion for Intervention.
  • The Regional Adjudicator denied the Motion for Reconsideration and the Answer-in-Intervention on February 21, 2002.
  • Petitioners filed a Petition for Review before the Court of Appeals on April 1, 2002. However, the petition was dismissed due to procedural defects: (1) the certification of non-forum shopping was signed only by Atty. Calo, not all petitioners, and (2) the petition lacked an affidavit of service.
  • Petitioners' Motion for Reconsideration was denied on May 28, 2002, prompting them to file a Petition for Review on Certiorari before the Supreme Court.

Issue:

  1. Whether the Court of Appeals erred in dismissing the petition purely on technical grounds, specifically:
    • The lack of proper verification and certification of non-forum shopping signed by all petitioners.
    • The absence of an affidavit of service as required by Section 13, Rule 13 of the Revised Rules of Civil Procedure.
  2. Whether the case should be remanded to the Court of Appeals for resolution on the merits.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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