Title
Caguioa vs. Bacolod-Murcia Farmers' Corp.
Case
G.R. No. L-13324
Decision Date
Oct 31, 1961
Farmers sought mandamus to compel sugar quota officials to sign permits; court upheld authority to enforce judgment, ordering substitutes to act.
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Case Summary (G.R. No. L-13324)

1. Background of the Case

  • On November 16, 1957, Hieroteo R. Villarosa and other members of the Bacolod-Murcia Sugar Farmers’ Corporation filed a petition for a writ of Mandamus against Salvador Pacis, the Permit Agent of the Sugar Quota Administration.
  • The petition aimed to compel Pacis to sign the quedan-permits for sugar milled and stored at the Bacolod-Murcia Milling Company.
  • The case was heard by Judge Eduardo E. Enriquez who required Pacis to respond within three days, which he did not comply with, leading to a hearing on November 22, 1957.

2. Court's Ruling

  • The court ruled on November 29, 1957, ordering Pacis to sign the permit portions of the quedan-permits immediately upon service of the decision.
  • The decision emphasized the urgency of the case and warned Pacis that disobedience would be punishable as contempt of court.

3. Execution of Judgment

  • Following the court's decision, a motion for immediate execution was filed by the petitioners, which led to a contested order on December 6, 1957, granting the motion.
  • The District Sugar Supervisor, Marcelo Caguioa, was directed to sign the quedan-permits in place of Pacis.

4. Subsequent Orders and Actions

  • Caguioa failed to comply with the court's order prompting further orders on December 11, 1957, which directed immediate delivery of the quedan-permits to the Sheriff and warned against contempt for non-compliance.
  • On December 28, 1957, Caguioa and Pacis filed a petition for Certiorari and Prohibition against the trial judge and Bacolod-Murcia Farmers' Corporation.

5. Grounds for Certiorari and Prohibition

  • The petitioners argued that:
    • The trial judge abused discretion in compelling Pacis to disobey orders from his superiors.
    • Caguioa was not a party to the original case, thus lacked the authority to act as a substitute for Pacis.

6. Court's Analysis and Conclusion

  • The court upheld the trial judge's authority to expedite proceedings and execute judgments based on the urgency expressed.
  • The court determined that Caguioa, as the District Sugar Supervisor, had the obligation to sign the permits and could be held in contempt for non-compliance.
  • The petition for Certiorari and Prohibition was dismissed, and the previously issued preliminary injunction was dissolved.

Key Definitions

  • Mandamus: A judicial remedy that compels a government official to execute a duty.
  • Quedan-permits: Documents required for the processing of sugar by the Sugar Quota Administration.
  • Contempt of court: The offense of being disobedient or disrespectful to a court of law.

Important Requirements and Timeframes

  • A response from Pacis was required within three days of service of the summons.
  • The court's decision was to be executed immediately upon service.
  • Caguioa was summoned to appear in court to show cause for his non-compliance on January 11, 1958.

Penalties and Consequences

  • Non-compliance with the court's orders may result in contempt of court proceedings.
  • Costs of litigation were assessed against the petitioners.

Cross-References

  • Rule 39, Sections 2, 9, 10: Governs the execution of judgments and the authority of the court to dir
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