Title
Chavez vs. Court of Appeals
Case
G.R. No. 174356
Decision Date
Jan 20, 2010
A landowner and tenant dispute over profit-sharing and property administration, involving claims of forum shopping and improper receivership, dismissed for lack of jurisdiction.

Case Digest (G.R. No. 174356)
Expanded Legal Reasoning Model

Facts:

  • Parties and Property
  • Respondent Fidela Y. Vargas owned a five-hectare mixed coconut land and rice fields in Sorsogon.
  • Petitioners Evelina G. Chavez and her daughter, Aida C. Deles, resided on a remote portion of the land, planting coconut seedlings and supervising coconut and palay harvests.
  • Agreement and Dispute
  • Fidela and Evelina agreed to divide equally the gross sales of all products; Evelina would hold Fidela’s share in trust.
  • Fidela later claimed Evelina failed to remit her share and, despite demands, refused to cede administration of the property.
  • Procedural History
  • Fidela filed with the RTC of Bulan, Sorsogon a complaint for recovery of possession, rent, and damages, praying for the immediate appointment of a receiver.
  • Evelina and Aida answered that the RTC lacked jurisdiction, as the dispute involved agrarian matters; the RTC dismissed the complaint for lack of jurisdiction, deeming them tenants.
  • Fidela appealed to the Court of Appeals (CA) and moved for receivership; on April 12, 2006, the CA granted receivership of the land.
  • Concurrently, Fidela filed estafa cases in the RTC of Olongapo City and a dispossession complaint with DARAB, all seeking receivership over the same property.

Issues:

  • Forum Shopping
  • Whether Fidela is guilty of forum shopping by filing identical receivership applications in multiple forums.
  • Receivership Grant
  • Whether the CA erred in granting Fidela’s application for receivership over the property.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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