Case Summary (G.R. No. 59762)
Background of the Agrarian Relationship
In 1954, Catorce was established as a tenant over a 0.7065-hectare parcel of irrigated rice land in Sta. Cruz, Buhi, Camarines Sur, with conditions that allowed him to share in the harvest at a rate of one-fourth for the landowner and three-fourths for himself. After being able to cultivate rice twice a year, the land was mortgaged by Merilles in 1960 to Andrea Bagayawa, mother of respondent Pedro Bagayawa. Following the mortgage, Andrea began receiving the landowner’s share from Catorce’s harvest.
Dispossession of the Petitioner
Catorce was dispossessed of the land in October 1977 when Andrea Bagayawa took over the cultivation without consent. Despite efforts to reclaim possession through mediation, Catorce faced resistance from both Andrea and her son, Pedro Bagayawa. Catorce's attempts to address the situation, including filing a complaint with the Agrarian Court in January 1980, were unsuccessful due to procedural issues.
Legal Proceedings and Initial Judgment
After Andrea's death in January 1980, her son Pedro became the possessor of the land. On November 20, 1980, Catorce filed a new complaint for reinstatement, which was initially unopposed as Pedro failed to respond within the required time. Consequently, the Agrarian Court ruled on April 22, 1981, in Catorce's favor, recognizing him as the bona fide tenant and granting various forms of relief, including reinstatement and damages.
Attempt to Set Aside Default Judgment
Pedro subsequently filed motions to set aside the Agrarian Court's default judgment, asserting that he was not negligent and had a valid defense. These motions were ultimately denied on June 18, 1981. Pedro later filed a notice of appeal, arguing that Catorce's action had prescribed since the complaint was filed more than three years after the ejectment, as mandated by Section 38 of Republic Act No. 3844.
Court of Appeals Ruling
On January 18, 1982, the Appellate Court sided with Pedro, ruling that the time limit for Catorce to file the action had expired. The court failed to take into account Catorce's earlier complaint filed on January 9, 1980, dismissing it due to procedural non-compliance, which should have reset the prescriptive period.
Supreme Court Decision and Rationale
The Supreme Court reversed the Appellate Court's decision, determining that Catorce's original filing effectively protected his right to pursue restitution. The Court clarified that the proper reckoning of the prescriptive period should
...continue readingCase Syllabus (G.R. No. 59762)
Case Background
- Petitioner Filomeno Catorce, identified as a pauper litigant, sought a review of the Court of Appeals decision that overturned a favorable judgment from the Court of Agrarian Relations.
- The case involved a dispute over agricultural tenancy rights and the possession of a parcel of land in Sta. Cruz, Buhi, Camarines Sur.
Facts of the Case
- In 1954, Catorce was recognized as the tenant of a 0.7065-hectare irrigated rice land owned by Simeona Merilles.
- The tenancy agreement included a sharing system where Catorce would receive 3/4 of the harvest.
- The land was cultivated twice a year, with significant yields of up to 25 cavans of rice per cropping season.
- In 1960, Merilles mortgaged the property to Andrea Bagayawa, who thereafter claimed the landowner's share of the harvest.
- Andrea Bagayawa seized possession of the land in October 1977 without Catorce’s consent, leading to a series of disputes over possession and rights to the harvest.
Proceedings Before the Agrarian Court
- Catorce attempted to regain possession through the Office of the Ministry of Agrarian Reform, which mediated without success.
- Catorce filed a complaint in January 1980, but it was dismissed due to failure to comply with the Lupon Pambarangay requirement under Presidential Decree No. 1508.
- Following Andrea's death in January 1980, her son, Pe