G.R. No. 212778 - Castro vs. Mendoza, Sr.

The case involves a parcel of land originally registered under Transfer Certificate of Title No. T-20427 in the name of Simeon Santos and his spouse, Laura Cruz.
Following Simeon Santos’ death, his compulsory heirs partitioned the property through an extrajudicial partition with waiver of rights and sale on May 16, 1977.
A portion of the land, measuring 2,132.42 square meters, was sold by one of the heirs, Jesus Santos, to the respondent Municipality of Bustos, Bulacan for P1.2 million, to enable the expansion and construction of the Bustos Public Market.
The surroundings of the first public market, including the original agricultural lot, were reclassified as a commercial area around 1989.

Petitioners Teddy Castro and Lauro C. Sebastian are agricultural tenants who had been in actual possession, occupation, and cultivation of the original Santos property since July 1981.
Petitioners claimed a right of redemption over the disputed 2,132.42 square meter parcel even after its sale to the municipality, basing their claim on their status as agricultural tenants.
Private respondents include Pablito V. Mendoza, Sr. (acting for a group organized as Bustos Public Market II Vendors and Stall Owners Association) who, as lessees and market stall vendors, claimed an interest in the property.

The Provincial Agrarian Reform Adjudicator (PARAD) initially ruled in favor of the petitioners, holding that they were the bona fide tenants entitled to redeem the property, and issued various orders (resolutions, writs of execution and possession, and orders directing corrective measures).
The DARAB later affirmed petitioners’ status as tenants but modified the ruling by directing the respondent Municipality to pay disturbance compensation instead of reinstating possession or allowing redemption.
On appeal, the Court of Appeals (CA) reinstated the PARAD’s original ruling with a modification that ordered both Jesus Santos and the Municipality jointly to pay moral damages and attorney’s fees; the decision attained finality on November 27, 2003.

Petitioners, through further motions, sought the execution of a deed of conveyance, issuance of a writ of possession, and, eventually, the transfer of ownership in their favor by executing various orders and resolutions from PARAD from 2006 to 2007.
PARAD’s orders (including a Resolution dated August 23, 2006 and one dated June 8, 2007) ordered the issuance of a writ of possession, the execution of a deed of conveyance, and other measures intended to effectuate the redemption of the property.
Private respondents filed numerous motions challenging these orders on various grounds, including lack of timely intervention and questioning the adequacy of the redemption price.

Private respondents, claiming that as market stall vendors they had a real, material interest in the property (albeit derived from a lease with the respondent Municipality), sought to intervene in the agrarian case.
The CA eventually granted their intervention on a real-party-in-interest basis even though it required application of rules traditionally used in civil cases and raised issues of locus standi.
A petition for review on certiorari and mandamus was subsequently filed, assailing the reversal and setting aside of PARAD issuances, citing grave abuse of discretion and alleging that many issuances were filed beyond the 60-day reglementary period.

Whether private respondents, as market stall owners and lessees in the public market, possess a sufficient material interest separate and distinct from the respondent Municipality to intervene in the agrarian case.
Whether their intervention under the doctrine of locus standi is proper given their status derived from a lease versus the municipality’s ownership.

Whether the PARAD correctly amended its June 28, 1995 Decision—originally recognizing petitioners’ right of redemption—by ordering the transfer of ownership despite finality and the absence of an adjudication on the redemption price or compliance with statutory requirements.
Whether the amendment falls within the exception of clarifying ambiguities in the dispositive portion or goes beyond the scope of the original decision.

Whether petitioners timely and validly exercised their right of redemption under Section 12 of Republic Act No. 3844 (as amended by RA 6389).
Whether the tender of redemption was effectively coupled with a full consignation of the redemption price (comparing the initial amount of P2,300.00 to the required P1.2 million) and whether it was done within the required period.

Whether petitioners, as agricultural tenants, could recover possession or even secure ownership of the property despite the public market’s existence and the reclassification of the land as commercial.
Whether the public use and construction of the market by the respondent Municipality precludes petitioners’ claim to ownership even if they possessed a right of redemption.