Case Digest (G.R. No. 125567)
Case Digest (G.R. No. 125567)
Facts:
Antonio (Antonino) Samaniego, Jose De La Cruz, John Samaniego, Ernesto Santos, Macario De La Cruz, Andres Pastorin, Benetrito De La Cruz, Jesus Batac and Rodolfo Laguisma v. Vic Alvarez Aguila, Josephine Taguinod and Secretary of the Department of Agrarian Reform, G.R. No. 125567, June 27, 2000, Supreme Court Second Division, Mendoza, J., writing for the Court.
Petitioners are tenant-farmers occupying an aggregate of about 10.4496 hectares in Patul (now Malvar), Santiago, Isabela, land titled in the name of Salud Aguila, whose children Vic Alvarez Aguila and Josephine Taguinod are the private respondents. The land was identified by the Department of Agrarian Reform (DAR) Region 2 as covered by the government’s Operation Land Transfer (OLT) program under P.D. No. 27. In 1976, Aguila, on behalf of her children, filed a petition for exemption from coverage under P.D. No. 27; petitioners opposed, alleging that Aguila’s transfer of title to her children violated DAR rules.
On August 21, 1991, the DAR Regional Director granted the exemption. The DAR Central Office affirmed that grant in a decision dated September 28, 1992. Petitioners thereafter moved the DAR, which reversed the affirmation and, by an order dated January 6, 1993, denied private respondents’ application for exemption and declared the petitioners the rightful farmer-beneficiaries of the subject landholdings.
Private respondents appealed the DAR’s January 6, 1993 order to the Office of the President, which, in a decision dated January 1, 1995, set aside the DAR’s January 6, 1993 order and confirmed and reinstated the DAR’s earlier September 28, 1992 order, with a modification declaring the land not covered by the OLT program. Petitioners filed a petition for review in the Court of Appeals. By decision dated January 25, 1996 (and resolution dated July 5, 1996), the Court of Appeals dismissed the petition for failure to implead the Office of the President as an indispensable party, citing the mandatory joinder doctrine. Petitioners’ motion for reconsideration in the Court of Appeals was denied.
Petitioners filed a petition for review on certiorari under Rule 45 with the Supreme Court, challenging the Court of Appeals’ dismissal and arguing that under Revised Administrative Circular No. 1-95 (governing appeals to the Court of Appeals from quasi-judicial agencies) the Office of the President need not be impleaded. The Supreme Court took up the case and resolved the limited procedural question whether the Office of the President is an indispensable party to such appeals.
Issues:
- Is the Office of the President an indispensable party that must be impleaded in an appeal to the Court of Appeals from its decision?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)