Cruz v. Dollete
REITERATIONFacts
The Antecedents: Spouses Sulpicio Dollete and Lourdes Barcelon filed a petition before the Court of Agrarian Relations alleging they were tenants of Jose de la Cruz in a palay landholding. They claimed that from 1956 to 1958, they furnished working animals and farm implements, shouldered cultivation expenses, but respondent took all the produce without giving them their rightful share. They further alleged threats to their lives if they insisted on liquidation and that they were dismissed without justification on February 14, 1959, with their landholding being worked by Revellano Fuentes. They prayed for their share of the produce, reinstatement, and for Fuentes to vacate. Procedural History: Respondent Jose de la Cruz denied the tenancy relationship, asserting he leased the land to Eliseo Condino since January 2, 1955. At the hearing, evidence was presented by both parties, including a lease contract (Exhibit "1") between De la Cruz and Condino. Judge Dacayo, finding the issues dependent on the determination of the real landlord and the validity of the lease contract, ordered the reopening of the case for additional evidence. However, Judge Dacayo was transferred, and Judge Ramon Blanco took his place. Without further proceedings, Judge Blanco rendered a decision on October 4, 1960, ordering respondent De la Cruz to pay petitioners 19 cavans of palay as damages and P50.00 as attorney's fees. A motion for reconsideration was denied. The Petition: Petitioner Jose de la Cruz filed a petition for certiorari, assailing the decision and order of Judge Blanco, arguing that Judge Blanco erred in rendering a decision that effectively reversed a prior order of Judge Dacayo without further proceedings, and in disregarding the lease contract (Exhibit "1") whose genuineness and due execution were not denied.
Issue(s)
Whether the respondent judge erred in rendering a decision that effectively reversed and set aside a prior interlocutory order of a former judge of the same court without further proceedings. Whether the respondent judge erred in disregarding the lease contract (Exhibit "1") between the petitioner and a third person.
Ruling
The petition is dismissed. The decision and order of the Court of Agrarian Relations, Eighth District, Iloilo City, dated October 4, 1960, and November 17, 1960, respectively, are affirmed.
Ratio Decidendi
On the first issue: The Court held that the order issued by Judge Dacayo on August 3, 1960, directing the reopening of the case, was merely an interlocutory order and not a final decision on the merits. As such, it was not appealable and could be modified, disregarded, or set aside by the court before a judgment on the merits was rendered. The Court cited Alvaran, et al. vs. Pingol (G.R. No. L-9201, May 31, 1957) to support the principle that a judge of a court is not prohibited from setting aside an interlocutory order of the same court rendered by a different judge. Therefore, Judge Blanco acted within his authority in rendering the decision complained of, as the prior order was not final and binding. On the second issue: The Court found no error in Judge Blanco's disregard of the lease contract (Exhibit "1"). It noted that the former judge, Judge Dacayo, had already observed that the petitioners had "objected vigorously" to the acceptance of Exhibit "1" and had attempted to show that no such lease contract was ever executed. Judge Blanco, who replaced Judge Dacayo, also found flaws in the evidence presented regarding the due execution of Exhibit "1", thus disregarding its probative value. The Court emphasized that findings of fact of the lower court, when supported by substantial evidence, cannot be disregarded. In this case, there was considerable evidence that the petitioners were indeed tenants cultivating the land for three years, which supported the lower court's findings in favor of the petitioners.
Main Doctrine
An interlocutory order directing the reopening of a case for reception of additional evidence, not being a final judgment on the merits, may be modified, disregarded, or set aside by the court before a decision on the merits is rendered. A judge of a court is not prohibited from setting aside an interlocutory order of the same court rendered by a different judge.