Title
Magbanua vs. Intermediate Appellate Court
Case
G.R. No. L-66870-72
Decision Date
Jun 29, 1985
Share tenants sued landowners for diverting water, damaging crops, and forcing eviction; SC awarded moral, exemplary damages, and attorney’s fees for rights violation.
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Case Digest (G.R. No. L-66870-72)

Facts:

    Parties and Proceedings

    • 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.

    Allegations and Claims

    • 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.

    Trial Court Ruling

    • 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.

    Appellate Court Decision

    • 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.

    Petition for Reinstatement

    • 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.

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)

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