Case Digest (G.R. No. 109568)
Facts:
- Rolando Sigre is the petitioner against the Court of Appeals and Lilia Y. Gonzales, co-administratrix of Matias Yusay's estate.
- Lilia Y. Gonzales filed a petition for prohibition and mandamus with the Court of Appeals on September 15, 1992 (CA-G.R. SP No. 28906).
- Gonzales aimed to prevent the Land Bank of the Philippines (LBP) from accepting leasehold rentals from Ernesto Sigre, Rolando's predecessor, and sought the return of previously remitted rentals.
- Ernesto Sigre was a tenant on irrigated rice land in Barangay Naga, Pototan, Iloilo, initially paying Gonzales 16 cavans per crop or 32 cavans per agricultural year.
- In the 1991-1992 agricultural year, Sigre stopped payments to Gonzales and began remitting them to the LBP, following DAR Memorandum Circular No. 6, Series of 1978.
- This circular stated that once the land's value was established, lease rental payments to landowners would cease, and tenants would pay the LBP.
- Gonzales claimed she was unaware that the DAR had fixed the land's production value at P13,405.67 prior to October 1972.
- On March 22, 1993, the Court of Appeals declared Memorandum Circular No. 6 null and void, ordered the LBP to return the lease rentals to Gonzales, and directed Sigre to pay rentals directly to her.
- Rolando Sigre and the LBP contested this ruling, leading to the consolidation of their petitions for review (G.R. No. 109568 and G.R. No. 113454).
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted the consolidated petitions of Rolando Sigre and the Land Bank of the Philippines.
- The decision of the Court of Appeals was nullified and set aside....(Unlock)
Ratio:
- The Supreme Court found that the Court of Appeals misinterpreted the relationship between DAR Memorandum Circular No. 6 and Presidential Decree No. 816.
- The Court emphasized that subordinate legislation, like the Memorandum Circular, is valid if it aligns with the law's objectives and do...continue reading
Case Digest (G.R. No. 109568)
Facts:
The case involves Rolando Sigre as the petitioner against the Court of Appeals and Lilia Y. Gonzales, who serves as the co-administratrix of the estate of Matias Yusay, the respondents. The events leading to this case began when Lilia Y. Gonzales filed a petition for prohibition and mandamus with the Court of Appeals on September 15, 1992, under CA-G.R. SP No. 28906. She sought to prevent the Land Bank of the Philippines (LBP) from accepting leasehold rentals from Ernesto Sigre, the predecessor of Rolando Sigre, and demanded that the LBP return the rentals previously remitted to it by Sigre. Ernesto Sigre had been a tenant on an irrigated rice land in Barangay Naga, Pototan, Iloilo, where he was originally paying Gonzales a lease rental of sixteen (16) cavans per crop or thirty-two (32) cavans per agricultural year. However, during the agricultural year of 1991-1992, Sigre ceased payments to Gonzales and instead began remitting them to the LBP, following the guidelines set forth in the Department of Agrarian Reform's (DAR) Memorandum Circular No. 6, Series of 1978. This circular stipulated that once the value of the land was established, payments of lease rentals to landowners would terminate, and tenant-farmers would then remit payments to the LBP. Gonzales claimed she was unaware that the DAR had fixed the land's production prior to October 1972, establishing its value at P13,405.67. The Court of Appeals ruled on March 22, 1993, declaring the Memorandum Circular No. 6 null and void, ordering the LBP to return the lease ren...