Santos v. Acosta
REITERATIONFacts
The Antecedents: Mariano Acosta, et al., filed a petition with the Court of Agrarian Relations seeking a readjustment of the sharing ratio and other related matters concerning their tenancy relationship with Hacienda de Santos No. 5. Alberto de Santos was impleaded as a respondent in his capacity as the manager of the hacienda. Procedural History: The case was submitted to arbitration, and an award was rendered by Judge Arsenio C. Roldan, directing a reliquidation. Based on this reliquidation, the Court of Agrarian Relations issued an order awarding specific amounts of palay to the tenants. Upon non-compliance, a writ of execution was issued, directing the provincial sheriff to collect the amounts due or their cash equivalent, and to levy upon the properties of the respondents, including Alberto de Santos. The Petition: Alberto de Santos filed a motion to quash the writ of execution insofar as it required the levy upon his personal properties, arguing that he was involved in the case solely as the manager of the hacienda and not in his personal capacity. This motion was denied by the agrarian court, leading to the present petition for review, where petitioner claims the agrarian court acted in excess of its jurisdiction.
Issue(s)
Whether the agrarian court acted in excess of its jurisdiction in ordering the levy upon the personal properties of Alberto de Santos in the writ of execution. Whether Alberto de Santos, impleaded only as manager of the hacienda, can be held personally liable for the award and have his personal properties levied upon.
Ruling
The Supreme Court set aside the orders of the agrarian court. It ordered that the writ of execution be modified to exclude the properties belonging to Alberto de Santos and to limit its scope to the properties owned by the owner of the hacienda.
Ratio Decidendi
On Issue 1: The Supreme Court held that the agrarian court acted in excess of its jurisdiction in ordering the levy upon the personal properties of Alberto de Santos. The Court clarified that the original and amended petitions clearly identified Hacienda de Santos No. 5 as the real party respondent, with Felipe de Santos as the owner. Although Alberto de Santos was included as a co-respondent, it was solely in his capacity as the manager of the hacienda. The issues involved pertained to the reliquidation of harvests from the hacienda, making the owner the sole party in interest affected by the petition. Therefore, it was improper to subject the manager's personal properties to the execution of the award. On Issue 2: The Court found it unfair and improper to make Alberto de Santos personally liable for the satisfaction of the award or to order the levy upon his personal property. There was nothing in the award that indicated he was made personally liable for any withheld palay. His intervention in the case was strictly in his capacity as manager of the hacienda. Consequently, the agrarian court's action in including his personal properties in the writ of execution was deemed an act clearly in excess of its jurisdiction. The Court noted that the owner of the hacienda was known, and sufficient properties belonging to the hacienda could be ascertained for the execution without implicating the properties of a person foreign to the case in his personal capacity, suggesting an intent to cause unnecessary harassment to the petitioner.
Main Doctrine
The Supreme Court held that the Court of Agrarian Relations acted in excess of its jurisdiction when it ordered the levy upon the personal properties of Alberto de Santos, who was impleaded only in his capacity as manager of the hacienda and not in his personal capacity. The Court emphasized that the real party in interest was the owner of the hacienda, and it is his properties that should be subject to the writ of execution, not those of the manager who has no personal liability for the award.