G.R. No. L-30821 - Bernardo vs. Court of Appeals

The case involves a petition for review by certiorari that has been pending for seventeen years.
The Supreme Court requested the parties to indicate their interest in prosecuting the case or if it has become moot.
Petitioners' counsel has not communicated with them for over ten years, leaving their interest in the case unknown.
Respondent Tropical Homes, Inc. and its counsel could not be located at their registered addresses.
Despite these circumstances, the Court decided to resolve the case rather than dismiss it as moot.

On January 29, 1969, petitioners Vidal Bernardo and Jesus Silverio filed a complaint with the Court of Agrarian Relations against Tropical Homes, Inc. and Mercedes Tomas.
The complaint alleged that the petitioners were agricultural lessees of a 2-hectare rice landholding and that Tropical Homes, in conspiracy with Tomas, bulldozed part of their land without notice or consent.
The petitioners sought a writ of preliminary injunction to prevent further bulldozing.
The Court of Agrarian Relations issued a temporary restraining order on January 31, 1969, prohibiting the respondents from further actions on the land.

Tropical Homes filed motions to lift the restraining order and to stay proceedings, claiming the need for a certiorari petition to nullify the order.
The Court of Agrarian Relations held the hearing on the preliminary injunction in abeyance pending the resolution of the certiorari petition.
A writ of preliminary injunction was issued by the Supreme Court on February 17, 1969, after the posting of a bond.

The Court of Appeals ruled in favor of Tropical Homes, stating that the restraining order was irregularly issued without a prior hearing or bond, as required by the New Rules of Court.
The Court interpreted Section 14 of the Code of Agrarian Reform, asserting that ejectment proceedings should only take precedence when the owner or a family member converts the land in good faith.

The Supreme Court was tasked with determining the validity of the restraining order and the application of Sections 14 and 36(1) of R.A. 3844.
The procedural issue was highlighted, emphasizing that laws of procedure may be retroactively applied if no substantial rights are impaired.
The Court noted that the restraining order issued by the Court of Agrarian Relations was distinct from a preliminary injunction and did not require a bond or prior hearing.

The Court affirmed the discretion of the Agrarian Court judge in issuing the restraining order, recognizing the potential for grave injury to agricultural lessees.
The Court acknowledged the importance of security of tenure for agricultural lessees and the need to protect their rights against dispossession.

The Supreme Court disagreed with the Court of Appeals' interpretation regarding the precedence of ejectment proceedings.
The Court emphasized that the purchaser of the land is bound to respect the rights of the agricultural lessee, maintaining the leasehold relationship by operation of law.
The Court reiterated that dispossession of agricultural lessees can only occur through a final court order.