Case Digest (G.R. No. L-46073)
Facts:
Heirs of Juan Cuano, represented by Francisca Cuano Aguilar, Precila Cuano Panotes and Rafael Obusan v. Hon. Court of Appeals and Pedro Ibana, G.R. No. L-46073, August 13, 1986, Supreme Court Second Division, Paras, J., writing for the Court.Petitioners are the alleged owners of a four-hectare parcel in Barrio Binanwaan, Talisay, Camarines Norte; Pedro Ibana (private respondent) cultivated the land as tenant since 1933. The parties operated under a 50/50 share-tenancy arrangement until the mid-1960s, when factual disputes over possession and abandonment arose. In February 1964, Pedro Ibana left temporarily to visit a sick daughter in Jomalig, leaving the standing palay in the care of his son Artemio; Ibana returned and continued cultivation through the 1966 “tambay” crop, when he sought to convert to the leasehold system with assistance from the Office of the Agrarian Counsel, a move the landowners refused.
The landowners filed Civil Case No. 56 (forcible entry) in the Municipal Court of Talisay; a writ of preliminary mandatory injunction issued and, after noncompliance, Pedro Ibana was cited for contempt and fined P50, and he then relinquished possession. While that civil case was pending, Pedro Ibana filed CAR Case No. 288-CN '67 for illegal ejectment, reinstatement and damages with the Court of Agrarian Relations (CAR). On April 25, 1967, the CAR dismissed Case No. 288 without prejudice for multiplicity of suits pending resolution of the municipal forcible entry case.
The Municipal Court made its preliminary injunction permanent but on appeal the Court of First Instance in Civil Case No. 1866 held the matter was within the CAR’s jurisdiction and thus treated the Municipal Court’s decision as nullity. Thereafter, on July 20, 1971, Pedro Ibana filed CAR Case No. 352-CN '71 (a revival of the 1967 CAR case). The CAR ruled for Ibana, declaring him a de jure tenant (now agricultural lessee), ordering defendants to vacate and reinstate plaintiff, fixing provisional rentals and awarding damages and seedling value; it denied other claims and counterclaims.
The Court of Appeals, in CA-G.R. No. 06370-R, affirmed the CAR decision in toto. Petitioners then filed this petition for review on certiorari to the Sup...(Subscriber-Only)
Issues:
- Whether the prior dismissal of CAR Case No. 288-CN '67 without prejudice and the Municipal Court proceedings operate as res judicata against CAR Case No. 352-CN '71.
- Whether the Court of Agrarian Relations’ and the Court of Appeals’ factual findings (particularly that Pedro Ibana did not abandon the tenancy) are supported by evidence and thus binding.
- Whether the CAR correctly applied agrarian law in declaring Pedro Ibana a de jure tenant entitled to reinstatement, damages, provisional lease terms and unilateral change to leasehold, and whether intervening occupants (e...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)