G.R. No. L-12335 - Pagdanga vs. Court of Agrarian Relations

The case centers on the interpretation of Section 20 of the Land Reform Act of 1955 (Republic Act 1400), which prohibits the alienation of land during pending petitions for expropriation.
Section 20 reads:

"Upon the filing of the petition referred to in sections 12 and 16, the landowner cannot alienate any portion of the land covered by such petition except in pursuance of the provisions of this Act, or enter into any form of contract to defeat the purposes of this Act, and no ejectment proceedings against any tenant or occupant of the land covered by the petition shall be instituted or prosecuted until it becomes certain that the land shall not be acquired by the Administration."

The statute specifically contemplates a petition filed by tenants with the Land Tenure Administration, rather than a petition filed in court.

In Tenancy Case No. 1248-NE of the Court of Agrarian Relations, Second District, a decision was rendered on October 5, 1956.

The decision ordered the ejectment of Esteban Baligad and eight other tenants of Canuto Pagdanganan in Guimba, Nueva Ecija.
The judgment also authorized the respondents to admit other tenants in replacement.

On March 25, 1957, the tenants filed a motion for the stay of execution.
They based their motion on a December 1955 incident where a majority of the tenants in Hacienda Ilagan (where the respondents’ lands were located) filed a petition with the Land Tenure Administration for the acquisition of the Hacienda under RA 1400.

Acting pursuant to Section 20 of RA 1400, the court, through its Resolution dated April 15, 1957, quashed the writ of execution.
Subsequent to a motion to reconsider, the court clarified its resolution.

It stated that if the Land Tenure Administration took no definite steps towards acquisition within three months, the court would then be free to take appropriate action.

The stay of execution, asserting that the court lacked jurisdiction since its decision had already become final and executory.
The motion for reconsideration.

The petitioner argued that Section 20 applies only where a "petition" for expropriation has been filed in court.
He contended that the petition contemplated therein should not include those submitted to the Land Tenure Administration.

The petitioner denied that the Agrarian Court had the power to cancel the execution of a final judgment.
He pointed out that the execution of a final decision – one that had been effectively affirmed by the highest court – was beyond the court’s supervisory jurisdiction.
He further contended that Section 20 was inapplicable since the petition for expropriation was brought to the court's attention only after the ejectment judgment had become final and executory.

Does Section 20 of RA 1400 apply exclusively to petitions filed in court, or does it cover petitions submitted by tenants to the Land Tenure Administration?
Is strict compliance with the statutory provisions required even when the certificate of a petition merely indicates that it was “filed by supposed tenants” rather than being signed by a majority?

Does the Agrarian Court possess the authority to cancel the execution of an ejectment order that has become final and executory?
Can the cancellation of execution be justified under Section 20 when the petition for expropriation was reportedly brought to the court's notice only after the adverse judgment had attained finality?