Case Summary (G.R. No. 195814)
Background of the Case
On September 11, 1958, the Corporation filed a petition in Civil Case No. Q-3332, seeking to compel the People's Homesite & Housing Corporation (PHHC) to execute a deed of purchase for a portion of land in San Jose del Monte, Bulacan, totaling 752.4940 hectares. The case alleges that the PHHC officials refused to execute the deed despite prior approvals and compliance with contract terms. Subsequently, on September 19, 1958, the League filed a motion to intervene, claiming an interest in opposing the deed’s execution to protect their rights as tenants, fearing dispossession if the land were subdivided for residential purposes.
Court's Initial Ruling
The Court of First Instance denied the League's motion to intervene on September 29, 1958, citing that the League's interest was only contingent and did not meet the requirements for intervention as stipulated under Rule 13 of the Rules of Court. The League’s subsequent motion for reconsideration was also denied, leading to the filing of the petition for mandamus by the petitioners.
Legal Issues Presented
The primary legal issue revolves around whether the tenant-farmers, represented by the League, possess a sufficient legal interest in the property and the underlying litigation to justify their intervention. The petitioners assert that their interest arises from their status as tenants and their petition to the Land Tenure Administration (LTA) to acquire the land under the provisions of Republic Act 1400, which governs land reform.
Examination of Applicable Law
The petitioners rely on Section 20 of Republic Act 1400, which prohibits landowners from alienating land covered by a petition for acquisition filed by tenants. The League argues that their petition before the LTA grants them a right to intervene as their interests are directly linked to the outcome of the case. However, the court elaborated that mere filing of a petition does not suffice to suspend the landowner’s rights unless the LTA has actively taken steps to initiate expropriation.
Judgment and Rationale
The court concluded that the tenant-farmers' rights were contingent on the LTA's affirmative action pursuant to Sections 12 and 16 of Republic Act 1400, which outline the process for evaluating land for requisition and t
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Case Overview
- The case involves an original petition for mandamus and/or certiorari filed by the Hacienda Sapang-Palay Tenants League, Inc., and its president, seeking to overturn the order of the Court of First Instance of Rizal.
- The petitioners aimed to set aside the denial of their motion to intervene in Civil Case No. Q-3332 and to compel the respondent Judge to admit them as intervenors.
Background of the Case
- The Philippine Suburban Development Corporation (the Corporation), as the vendor, initiated a case against the People’s Homesite & Housing Corporation (PHHC), seeking to enforce a deed of sale for a portion of Hacienda de Sapang-Palay.
- The land in question consists of 752.4940 hectares, with a purchase price of P0.475 per square meter.
- The Corporation alleged that the contract was perfected and approved by the Cabinet but that PHHC officials refused to execute the deed of sale, causing damages.
Petition for Intervention
- On September 19, 1958, the Hacienda Sapang-Palay Tenants League, composed of tenant-farmers, filed a motion to intervene.
- The League argued that:
- They had a vested interest in the outcome, fearing dispossession if PHHC acquired the land for residential purposes.
- They had pe