G.R. No. 181071 - EspiNo. vs. People

The case involves an original petition for mandamus and/or certiorari filed by Hacienda Sapang-Palay Tenants’ League, Inc. (the League) and its president, Dominador Guevan.
The petitioners seek to set aside a previous order from the Court of First Instance of Rizal (Quezon City) which denied their motion to intervene in Civil Case No. Q-3332.
The disputed order was issued on September 29, 1958, and also addressed an unrelated question regarding the participation of Senator Francisco A. Rodrigo as counsel for the tenants.

The initial petition, later amended into a complaint for specific performance and damages, was filed on September 11, 1958, by the Philippine Suburban Development Corporation (later simply the Corporation).
The petition aimed to compel the People’s Homesite & Housing Corporation (PHHC), acting as vendee, to execute the deed of purchase for a one-half portion of Hacienda de Sapang-Palay (752.4940 hectares) located in San Jose del Monte, Bulacan.
The agreed price for the property was P0.475 per square meter, and the petition alleged that despite all approvals and conditions being met, PHHC officials refused to execute the deed, causing damages amounting to P1,500,000.00 plus additional attorney’s fees.

On September 19, 1958, the League, representing tenant-farmers of Hacienda Sapang-Palay, and its president filed an urgent motion to intervene in the litigation.
The League based its request for intervention on two principal contentions:

They claimed to have an interest in the success of PHHC’s resistance to executing the deed, arguing that should PHHC acquire the land, it would be subdivided for residential use, resulting in the dispossession of the tenant-farmers.
They stated that through their petition to the Land Tenure Administration (LTA) under Republic Act 1400, they had acquired legal rights in the property consistent with provisions of the law.

The lower court ruled against the League's motion to intervene on the ground that its interest in the property was merely contingent or expectant.
The decision emphasized that the League failed to establish a sufficient legal interest as required under Rule 13 of the Rules of Court, thus lacking the direct, immediate, and material interest necessary for intervention.
The issue concerning the appearance of Senator Rodrigo as counsel for the tenants was left undetermined by the court, given its focus on the sufficiency of the legal interest.

Whether the filing of a petition by tenant-farmers with the LTA under Republic Act 1400 conferred upon them a direct, immediate, and material legal interest in the property.
Whether the interest asserted by the League, being primarily contingent or expectant, meets the requirements under Rule 13 of the Rules of Court for intervention.

Interpretation of Section 20 of Republic Act 1400 and its impact on the rights of tenants vis-à-vis the landowner’s right of dominion (jus disponendi).
The necessary conditions (as detailed in Sections 12 and 16 of Republic Act 1400) that must be satisfied before the state’s right of eminent domain and the corresponding legal interest of the tenants may effectively materialize.

Whether the expected benefits from the petition to the LTA can justify allowing the League to intervene in the litigation concerning the deed of sale execution.
The potential conflict between protecting tenants’ interests and the property owner’s fundamental right to alienate his property until affirmative governmental action is taken.