Case Digest (G.R. No. 113220-21)
Facts:
Department of Agrarian Reform Adjudication Board (DARAB) and Fe Arche-Manalang, Department of Agrarian Reform (DAR), petitioners, v. Court of Appeals, BSB Construction and Agricultural Development Corporation, and Carol Baucan, G.R. Nos. 113220-21, January 21, 1997, Supreme Court Third Division, Davide, Jr., J., writing for the Court.The dispute arose over a 45-hectare parcel in Barangay San Isidro, Antipolo, Rizal. On March 10, 1993, Salvador O. Abogne, Artemio Catamora and Raul Ordan (hereafter the Abogne complainants) filed PARAD Case No. IV-0075-93 with the Provincial Agrarian Reform Adjudicator (PARAD) claiming they were farmworkers/occupant-tillers entitled to maintenance in peaceful possession of a 12-hectare portion; they alleged BSB Construction bulldozed improvements and sought injunctive relief. On the same day PARAD Fe Arche-Manalang issued a temporary restraining order (TRO) enjoining BSB Construction from further bulldozing.
On March 12, 1993 the petitioners (BSB Construction and related interests) filed a complaint with the DARAB seeking nullification of the PARAD restraining order, alleging the land was residential and the complainants were squatters. On March 19, 1993 petitioners filed a certiorari petition attacking the PARAD TRO as capricious and in excess of jurisdiction. The March 19 petition was docketed as CA-G.R. SP No. 30474 (the ABOGNE Case) before the Court of Appeals.
Separately, on May 6, 1993 another group (Lourdes Bea, Benjamin Enriquez and Natividad Enriquez — the Bea complainants) filed a complaint with the DARAB, essentially asserting the same claims to the same portion of the land. On May 6, 1993 the DARAB issued a status quo order (SQO) forbidding BSB Construction from bulldozing and directing enforcement measures pendente lite; that DARAB docketing was DARAB Case No. 0100-93 (Reg. Case No. IV-RI-0075), later styled CA-G.R. SP No. 31179 (the BEA Case). BSB Construction and Carol Baucan then filed a Rule 65 certiorari petition before the Court of Appeals to annul the DARAB SQO.
Before the Court of Appeals the parties contested, inter alia, whether the land was agricultural and thus within the scope of Republic Act No. 6657 (Comprehensive Agrarian Reform Law), whether the private respondents were tenant-farmers or squatters, whether the PARAD TRO was properly issued, and whether the DARAB had authority to issue the SQO while a similar matter was pending with the PARAD. On September 23, 1993 the Court of Appeals dismissed the certiorari and contempt motion in CA-G.R. SP No. 30474 (upholding the PARAD TRO or finding the petition premature) but granted certiorari in CA-G.R. SP No. 31179, declaring the DARAB SQO and all related proceedings (including a July 15, 1993 arrest order) null and void; it also ordered the PARAD to resolve the application for preliminary injunction in PARAD Case No. IV-RI-0075-93 within ten (10) days and enjoined petitioners from bulldozing pending that resolution. Petitioners filed a partial motion for reconsideration, which the Court of Appeals denied by resolution dated December 27, 1993.
Petitioners then filed the present petition for review under Rule 45 of the Rules of Court before the Supreme Court, seeking to set aside the...(Pro-only)
Issues:
- Did the Court of Appeals commit grave abuse of discretion in directing the PARAD to resolve the application for a writ of preliminary injunction within ten (10) days (i.e., did the appellate supervisory directive unlawfully interfere with quasi‑judicial proceedings or exceed supervisory power)?
- Did the Court of Appeals commit grave abuse of discretion in annulling the DARAB Status Quo Order of May 6, 1993 and all proceedings in DARAB Case No. 0100-93 (Reg. Case No. IV-RI-0075), including the arrest order (i.e., was the DARAB enti...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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