Case Summary (G.R. No. L-18664)
Factual Background
On September 25, 1959, Beatriz Vda. de Feliciano initiated an ejectment case against Ismael Calma, alleging that he had abandoned the land he was leasing, specifically citing negligence in fulfilling tenant obligations such as land preparation and timely transplanting of seedlings. Prior to this filing, an intervention was sought by Vda. de Feliciano where a report from Atty. Jose L. Santiago concluded that Calma had indeed shown negligence regarding the upkeep of the landholding.
Court Proceedings and Initial Orders
On the same day the ejectment petition was filed, a hearing was scheduled to determine whether to issue an interlocutory order. The court subsequently permitted Feliciano to cultivate the land using hired laborers while requiring her to post a bond of P500 to cover any potential damages to Calma. This order was later amended to restrain Calma from employing or appointing a tenant and to prevent him from disturbing the cultivation efforts by Feliciano.
Commissioner’s Recommendation
Calma answered the ejectment complaint with defenses and contestations of the allegations made by Feliciano. After conducting a hearing, Commissioner Yumul recommended dismissing the complaint on March 8, 1961, citing a lack of merits and allowing Calma to retain possession of the land, along with an award of attorney's fees to him.
Decision of the Court of Agrarian Relations
In contrast to the Commissioner's recommendation, the Court of Agrarian Relations rendered a decision on March 27, 1961, allowing Feliciano to eject Calma and confirming her authority to appoint a new tenant if desired. The court determined that Calma's actions were detrimental to the productivity of the land and therefore warranted eviction.
Petition for Certiorari and Legal Issues Raised
Calma sought to contest the decision through a petition for certiorari, raising concerns over jurisdiction, timeliness, and the sufficiency of the evidence supporting the court's ruling. The respondents argued that Calma's petition was filed out of time, pointing out that the motion for reconsideration was denied, and the subsequent certiorari petition was filed three
...continue readingCase Syllabus (G.R. No. L-18664)
Background of the Case
- The case involves Ismael Calma (petitioner) and Beatriz Vda. de Feliciano (respondent), concerning a parcel of riceland in San Agustin, Magalang, Pampanga.
- The land, approximately 3-1/2 hectares, was tenanted by Ismael Calma, who was accused of negligence regarding his responsibilities as a tenant.
Petition for Ejectment and Damages
- On September 25, 1959, Beatriz Vda. de Feliciano filed a verified petition for ejectment and damages against Ismael Calma, citing abandonment and negligence.
- Specific allegations of negligence included poor land preparation, haphazard cultivation, and delays in transplanting seedlings, which were detrimental to the landowner’s interests.
Mediation and Initial Court Proceedings
- Prior to the ejectment case, on September 23, 1959, Feliciano sought the Court of Agrarian Relations' intervention to assess the condition of the landholding.
- Atty. Jose L. Santiago was appointed to mediate and reported on September 24, 1959, confirming Calma's negligence.
Interlocutory Order and Subsequent Developments
- Following the initial hearing on September 25, 1959, a temporary order allowed Feliciano to manage the land using hired laborers, with a requi