Case Digest (G.R. No. 85869)
Case Digest (G.R. No. 85869)
Facts:
Anderson Co. and Jose Chua v. The Honorable Intermediate Appellate Court, The Honorable Bienvenido D. Chingcuangco, as Presiding Judge of Branch XCI, Quezon City, and Joveno Roaring, G.R. No. 65928, June 21, 1988, First Division, Cruz, J., writing for the Court. Justice Narvasa (Chairman) and Justice Grino‑Aquino took no part; Justices Gancayco and Medialdea concurred.The land at issue was originally owned by Toribio Alarcon and leased to the Republic Broadcasting System (DZBB) in 1955. Before and after World War II Miguel Alfonso tilled the parcel as an agricultural tenant; after Alfonso’s death in 1976 his son‑in‑law, Joveno Roaring (private respondent), who had assisted since 1968, continued cultivation without objection from DZBB. The lot was later acquired at foreclosure by the Philippine Commercial and Industrial Bank, transferred in 1979 to petitioner Anderson Co., which assigned its rights to petitioner Jose Chua.
Petitioners repeatedly demanded that Roaring vacate; administrative mediation failed. The National Housing Authority issued a clearance for demolition and, on November 22, 1980, Roaring’s house on the lot was demolished. Roaring then sued Anderson Co. and Napoleon Pobre (who participated in the demolition) for maintenance of possession and damages; Chua was later impleaded as an indispensable party.
The Court of Agrarian Relations (Quezon City) found Roaring to be a tenant and/or agricultural lessee, ordered Chua to maintain Roaring in peaceful cultivation, to recognize the tenancy relationship between DZBB and Roaring, to afford him an adequate right of way, and held Co, Chua and Pobre solidarily liable for P10,000 damages. On appeal the Intermediate Appellate Court affirmed the judgment but modified it by absolving Pobre from financial liability. Petitioners then sought relief before the Supreme Court by appeal under Rule 45; the petition was filed late, which petitioners admitted.
Issues:
- Was the petition to the Supreme Court properly filed and thus entertainable despite tardiness?
- Did the trial court have jurisdiction over the subject matter as an agrarian case in view of the Metro Manila Zoning Ordinance No. 81‑01 (1981)?
- Did Joveno Roaring qualify as a tenant‑farmer under R.A. No. 1199 despite being employed elsewhere and hiring helpers?
- Was the Republic Broadcasting System (DZBB) an indispensable party whose absence defeated the action?
- Was the award of damages and the trial court’s imposition of liability (including the role of Pobre) proper?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)