Bukid v. Reyes
REITERATIONFacts
The Antecedents: Crisanto Salazar alleged that he was a tenant of the spouses Laureano Macalintal and Irenea Acapio on two parcels of land since 1957. He claimed to have planted permanent trees and crops thereon. In 1972, after separating from his wife, Salazar demanded payment for the trees, but the Macalintal spouses allegedly refused and dispossessed him, asking Maria Bukid to administer the landholdings. Salazar prayed for an accounting of produce, restoration of possession, or payment for the trees plus disturbance compensation and damages. Procedural History: The Macalintal spouses, in their answer, claimed Salazar was their tenant only until 1967 when he abandoned the land. They asserted that Maria Bukid became their overseer and her sons, Miguel Castillo and Manuel Carandang, became their tenants. They further alleged that Salazar surreptitiously occupied their house on the land in February 1975, prompting them to file an ejectment suit. On December 10, 1975, Maria Bukid and her sons filed a complaint in intervention, claiming to be the overseer and tenants since 1967, and alleging Salazar forcibly entered the house and dislodged Maria Bukid. They sought recognition as overseer and tenants. Salazar opposed the intervention, while the Macalintal spouses did not object. The Court of Agrarian Relations (CAR) denied the motion for intervention on February 20, 1976, and denied a subsequent motion for reconsideration on March 23, 1976. The Petition: Maria Bukid and her sons filed a petition for certiorari and prohibition, questioning the CAR's denial of their intervention.
Issue(s)
Whether the respondent Judge of the Court of Agrarian Relations committed grave abuse of discretion in denying the motion for intervention filed by the current overseer and tenants of the landholdings in question.
Ruling
The Court resolved to set aside the order denying the motion for intervention and directed that the intervention complaint be admitted. The Court found that the denial of the motion for intervention was issued with grave abuse of discretion.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the petitioners possess an interest in the subject matter of the litigation that is actual and material, direct and immediate, rather than merely contingent or inchoate. Applying the standard in Garcia v. David (67 Phil. 279), the Court noted that intervention is proper when an intervenor will either gain or lose by the direct legal operation and effect of the judgment. In this case, because Salazar seeks to be restored to the possession of landholdings which have been under the control and tillage of the petitioners since 1967, any adjudication in Salazar's favor would necessarily prejudice the petitioners' tenure. Furthermore, Salazar's demand for a share of the produce for the period the land was in the petitioners' possession would adversely affect their own shares and rights to the plantings. The Court emphasized that complete relief cannot be granted without hearing the side of the intervenors, as their interests are directly intertwined with the controversy between Salazar and the Macalintal spouses. Finally, citing Toledo v. Court of Agrarian Relations (8 SCRA 499), the Court held that admitting the intervention would obviate a duplicity of suits and serve the interests of justice.
Main Doctrine
The Court of Agrarian Relations gravely abused its discretion in denying the motion for intervention of Maria Bukid and her sons, Miguel Castillo and Manuel Carandang, as they have an actual and material interest in the subject matter of the litigation between Crisanto Salazar and the Macalintal spouses, and complete relief cannot be granted without hearing their side, thus obviating duplicity of suits.