Case Digest (G.R. No. L-21156)
Facts:
Lourdes R. Osmena v. Court of Agrarian Relations, Hon. Valeriano A. Del Valle, Leonardo Quima and Filomeno Oldog, G.R. Nos. L-21156 and L-21187, July 30, 1966, the Supreme Court En Banc, Bengzon, J.P., writing for the Court.On April 17, 1961, Lourdes R. Osmena (petitioner) filed separate ejectment complaints in the Court of Agrarian Relations at Bacolod City against Leonardo Quima (Case No. 1558) and Filomeno Oldog (Case No. 1559), alleging ownership of Hacienda Esperanza and that each respondent-tenant had failed to pay agreed yearly rentals in palay for prior crop years. Respondents answered and filed counterclaims alleging illegal prevention from planting during the 1960–61 crop year; petitioner answered those counterclaims.
The parties executed identical amicable settlements on December 14, 1961, which they submitted to the Court of Agrarian Relations for approval. Each settlement recited admitted arrears for crop years 1958–59 and 1959–60, waived claims for 1960–61, and provided that the rentals for crop years 1961–62, 1962–63 and 1963–64 would be paid “on or before the harvest” of each respective crop year; it further stipulated that upon failure to fully pay any installment the landowner “shall immediately be entitled to ask for the execution of the judgment which this Honorable Court may render pursuant to this amicable settlement.”
The Court of Agrarian Relations, on March 7, 1962, approved and rendered judgment pursuant to the amicable settlements in both cases. On September 28, 1962, petitioner moved for execution, alleging respondents paid short for the 1961–62 rentals and had subleased the land without consent; the Court denied the motions on November 14, 1962, ruling execution was premature because the settlement covered installments through 1963–64 and that the alleged subleasing was a new matter not proper in a motion for execution. Motions for reconsideration were denied on March 16, 1963.
Petitioner filed a petition for review in this Court ...(Subscriber-Only)
Issues:
- Was petitioner’s motion for execution with respect to the unpaid rentals for crop year 1961–62 premature?
- Can a judgment rendered upon an amicable settlement be enforced by execution upon breach of its terms, or does such breach constitute a new cause of action re...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)