Case Digest (G.R. No. L-14502)
Case Digest (G.R. No. L-14502)
Facts:
Federico Pineda v. Domingo Cabangon, Associate Judge of the Court of Agrarian Relations, and Marcelino Tiamzon, G.R. No. L-14502. June 30, 1961, the Supreme Court En Banc, Padilla, J., writing for the Court.
Petitioner Federico Pineda filed two separate complaints in the Court of Agrarian Relations, Third Regional District, Tarlac, against tenant Marcelino Tiamzon (and others). On 27 July 1956 Pineda commenced case No. 182-Tarlac seeking an order directing the tenants to plant by the government-approved “Masagana System” and, should they refuse, for authority to dispossess them and for recovery of damages. On 2 August 1956 he filed case No. 190-Tarlac seeking dispossession of Tiamzon for allegedly failing to “take good care” of the land, asserting that Tiamzon had undertaken cultivation of another landholding without the landlord’s consent in violation of Section 24, Republic Act No. 1199.
The pleadings were amended (the 17 November 1956 and 27 June 1957 amendments increased claimed damages and added allegations of abandonment and neglect). Respondents answered and counterclaimed. Petitioner sought an ex parte ocular inspection; on 3 October 1957 the Court of Agrarian Relations directed a JAGO officer to inspect, who reported on 7 October 1957 that the tenant’s ricefields were weedy, attacked by pests (stem borers), and that much of the field showed little sign of cultivation. The Commissioner thereafter recommended ejectment.
On 23 July 1958 the Court of Agrarian Relations rendered judgment dismissing Pineda’s petitions, finding that the low yield was attributable to pest attack rather than neglect and that petitioner’s instructions regarding the Masagana System were insufficient; the Court ordered the petitioner to maintain respondent as tenant and denied attorney’s fees. Pineda’s motion for reconsideration was denied on 18 September 1958.
Pineda then filed in this Court a petition for a writ of certiorari on 9 October 1958 alleging grave abuse of discretion by the trial court. The Supreme Court initially dismissed the petition for lack of supporting papers on 31 October 1958, but on motion for reconsideration and after the filing of necessary papers the Court on 4 December 1958 ordered respondents to answer. The respondent Court of Agrarian Relations declined to answer as unnecessary; Tiamzon filed an answer contending the proper mode of review was a petition for review under Section 13, Republic Act No. 1267, as amended by Republic Act No. 1409, which permits only questions of law and must be filed within fifteen days. Petitioner relied on the ocular inspection report, the Commissioner’s recommendation, and alleged failures by the tenant to adopt the Masagana System to show grave abuse.
The issues presented involved mixed and predominantly factual allegations about cultivation, pests, and compliance with planting systems; the Supreme Court considered whether certiorari was the proper remedy and whether the petition was timely and sustainable.
Issues:
- Was the petition for a writ of certiorari the proper mode of review and, if not, was it filed within the statutory period for a petition for review under Section 13, Republic Act No. 1267, as amended by Republic Act No. 1409?
- Did the Court of Agrarian Relations commit grave abuse of discretion in dismissing Pineda’s petitions and ordering him to maintain Tiamzon as tenant?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)