Case Digest (G.R. No. L-66870-72)
Facts:
The case involves a dispute between petitioners Agapito Magbanua, Inenias Martizano, Carlito Herrera, Sr., Paquito Lopez, and Francisco Herrera against respondents Eduardo Perez and his siblings, Butch, Diego, and Nena, all surnamed Perez. This legal battle originated from circumstances in San Carlos City, Negros Occidental, where the petitioners, who were share tenants, asserted that the respondents unlawfully diverted the flow of irrigation water to their lands. This diversion resulted in significant damage to the petitioners' agricultural produce, as their land became parched and incapable of sustaining crops.
The trial commenced in the defunct Court of Agrarian Relations, wherein the petitioners claimed they were instructed by the respondents' overseer to vacate their lands due to an inability to plant their rice crops, effectively disrupting their tenancy rights. Consequently, the petitioners sought judicial declarations to be recognized as leasehold tenants and re
Case Digest (G.R. No. L-66870-72)
Facts:
- The petitioners—Agapito Magbanua, Inenias Martizano, Carlito Herrera, Sr., Paquito Lopez, and Francisco Herrera—alleged that they are share tenants.
- The respondents are Eduardo, Butch, Diego, and Nena, all surnamed Perez, who are accused of actions affecting the petitioners’ livelihood.
- The case consolidated agrarian cases (CAR Case Nos. 827, 828, and 829) handled previously by the defunct Court of Agrarian Relations in San Carlos City, Negros Occidental.
Parties and Proceedings
- Petitioners alleged that the respondents diverted the free flow of water from their farmlands, causing portions of their landholdings to dry up and significantly affecting their palay crops.
- It was further contended that the respondents’ overseer instructed the tenants to vacate the areas due to the inability to irrigate their lands, thereby hindering agricultural cultivation.
- Based on these allegations, the petitioners sought:
- A declaration that they were leasehold tenants entitled to the protection of their right to peaceful cultivation.
- An injunction to prevent the disruption of water supply to their farmlands.
Allegations and Claims
- The trial court declared the petitioners as agricultural lessees.
- It issued a permanent injunction prohibiting the respondents from interfering with the water supply.
- The court ordered:
- The petitioners to consult the Ministry of Agrarian Reforms for rent fixation.
- Awarding each of the six petitioners moral and exemplary damages of P10,000.00.
- Payment of attorney's fees amounting to P5,000.00.
- Dismissal of all other claims and counterclaims for lack of merit.
Trial Court Ruling
- The respondents appealed the trial court’s order.
- The Intermediate Appellate Court modified the trial court’s decision by:
- Eliminating the award of moral and exemplary damages.
- Stripping the award of attorney’s fees, holding that there was no evidence of fraudulent or bad faith conduct by the respondents.
- Affirming the remainder of the trial court’s decision and ordering costs against the appellants.
Appellate Court Decision
- The petitioners filed a petition seeking the reinstatement of the moral and exemplary damages and attorney's fees.
- They argued that the actions of the respondents in diverting irrigation water and forcing them off their lands amounted to a breach of their rights, warranting the awards previously granted by the trial court.
- Photographic evidence and other manifestations submitted by the petitioners were noted as unrefuted, supporting their claim of harm.
Petition for Reinstatement
Issue:
- Whether the actions of diverting water supply and ordering the tenants to vacate constituted a disturbance of possession and a violation of the tenants’ right to peaceful cultivation.
- Whether the respondents’ conduct amounted to wrongful interference that justifies the awarding of moral and exemplary damages under the Civil Code.
- Whether the Intermediate Appellate Court erred in eliminating the trial court’s award of moral and exemplary damages as well as the attorney's fees.
- Whether the petitioners, as tenants, are entitled to recover attorney’s fees under the circumstances, given the evidence of the respondents’ oppressive actions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)