Heirs of Restrivera v. De Guzman
REITERATIONFacts
The Antecedents: Petitioners, heirs of Geronimo Restrivera and others, filed a complaint for maintenance of peaceful possession with a prayer for injunctive relief against respondents, heirs of Pedro Ermitaño. Petitioners claimed to be bona fide tenants cultivating an agricultural land owned by Ermitaño, to whom they paid rentals. Following Ermitaño's death, respondents allegedly ordered petitioners to vacate the land, fenced it, and posted armed guards, prompting the legal action to restore their possession and determine rental obligations. Procedural History: The case originated with two consolidated complaints before the Provincial Agrarian Reform Adjudicator (PARAD). The PARAD initially ruled against the petitioners, finding them not to be bona fide tenants and ordering them to vacate. This decision was appealed to the Department of Agrarian Reform Adjudication Board (DARAB). During the appeal, Tricom Development Corporation (TRICOM), claiming to have purchased the land, filed a motion for intervention. The DARAB initially denied TRICOM's intervention but later reconsidered, allowing intervention and holding its prior decision in abeyance. Subsequently, the DARAB modified its earlier decision, ordering the petitioners to vacate in favor of TRICOM. Petitioners then filed a petition for mandamus with the Court of Appeals, which was amended to include certiorari and prohibition. The Court of Appeals affirmed the DARAB's modified decision, leading to the present petition. The Petition: Petitioners seek review on certiorari under Rule 45 of the Rules of Civil Procedure, assailing the Court of Appeals' decision. They argue that the Court of Appeals erred in finding that the DARAB's October 5, 1998 decision had not become final and executory, in allowing TRICOM's intervention in one consolidated case but not the other, in deeming the December 27, 1999 DARAB decision as a follow-through of a prior resolution, and in concluding that the failure to file a motion for reconsideration was fatal. Petitioners primarily contend that the DARAB acted without or in excess of jurisdiction by allowing TRICOM's intervention and by suspending and withdrawing its earlier decision despite its alleged finality.
Issue(s)
Whether the Court of Appeals erred in finding that the consolidated DARAB Decision dated October 5, 1998 never became final and executory because its effectivity was held in abeyance by DARAB Resolution dated March 4, 1999. Whether the Court of Appeals erred in finding that TRICOM's intervention in DARAB Case No. DCN-6060 is essentially an intervention also in DARAB Case No. DCN-6086, and whether TRICOM's Motion for Intervention was proper and timely. Whether the Court of Appeals erred in finding that the DARAB Decision dated December 27, 1999, which is in the nature of an amended judgment, is a 'follow through' of the March 4, 1999 DARAB Resolution. Whether the Court of Appeals erred in finding that petitioners' failure to file a motion for reconsideration of the DARAB Decision dated December 27, 1999, is fatal to their case. Whether the Court of Appeals erred in finding that there was no grave abuse of discretion on the part of respondent DARAB in issuing the questioned Decision dated December 27, 1999. Whether the suspension of the DARAB Decision dated October 5, 1998 was proper.
Ruling
The petition is denied. The assailed Decision dated July 31, 2000, and Resolution dated December 26, 2000, of the Court of Appeals in CA-G.R. SP No. 54267 are affirmed.
Ratio Decidendi
On the finality and executory nature of the October 5, 1998 Decision: The Court agreed with the Court of Appeals that the consolidated decision dated October 5, 1998, had not become final and executory. This was because its effectivity was explicitly held in abeyance by the DARAB Resolution dated March 4, 1999, pending the determination of TRICOM's intervention. Since the decision never attained finality, there could be no issuance of a writ of execution thereon, as execution can only issue upon a final order or decision that finally disposes of the action or proceeding. On the propriety and timeliness of TRICOM's intervention: The Court held that the allowance or disallowance of a motion to intervene is addressed to the sound discretion of the court. This discretion cannot be reviewed by certiorari or controlled by mandamus unless exercised arbitrarily or capriciously. In this case, TRICOM demonstrated a legal interest in the subject property, having acquired it through a Deed of Assignment and a Deed of Sale on Installments. As a purchaser, TRICOM has a direct and material interest that could be adversely affected by the judgment, thus giving it standing to intervene. The Court reiterated that intervention should be accorded to anyone having title to property under litigation, provided their right will be substantially affected by the decision and it is reasonably necessary to safeguard their interest. The Court found that TRICOM's motion for intervention was seasonably filed. Section 2, Rule 19 of the 1997 Rules of Civil Procedure allows intervention at any time before the rendition of judgment by the trial court. TRICOM filed its motion on January 29, 1998, which was before the DARAB rendered its Decision on October 5, 1998. Therefore, the motion was filed within the prescribed period. On the nature of the DARAB Decision dated December 27, 1999: The Court found that the DARAB Decision dated December 27, 1999, which modified the earlier decision and ordered the complainants to vacate in favor of TRICOM, was a logical follow-through of the March 4, 1999 DARAB Resolution. This resolution allowed TRICOM's intervention and held the October 5, 1998 decision in abeyance, thereby opening the door for further amendments and a final determination of the parties' rights, including those of the intervenor. On the failure to file a motion for reconsideration: The Court upheld the Court of Appeals' finding that the petitioners' failure to file a motion for reconsideration of the DARAB Decision dated December 27, 1999, was fatal to their cause. This failure meant that the DARAB decision became final and executory as far as the petitioners were concerned, and they could no longer assail it before the Court of Appeals through a petition for certiorari, prohibition, and mandamus. On the absence of grave abuse of discretion: The provided text does not explicitly address whether the Court of Appeals erred in finding that there was no grave abuse of discretion on the part of respondent DARAB. Therefore, no corresponding ratio can be provided based on the given information. On the suspension of the DARAB Decision dated October 5, 1998: The Court found no error or grave abuse of discretion on the part of the DARAB in suspending the effectivity of its October 5, 1998 Decision. The DARAB Resolution dated March 4, 1999, which allowed TRICOM's intervention, also held the earlier decision in abeyance to ascertain all substantive rights of the parties, especially TRICOM's claim as an intervenor. This action was deemed imperative in the interest of justice to avoid grave injustice to TRICOM, the alleged rightful owner, and to harmonize the judgment with justice. The Court affirmed that a court may modify or alter its judgment to harmonize it with justice.
Main Doctrine
The allowance or disallowance of a motion to intervene is addressed to the sound discretion of the court, and such discretion, once exercised, cannot be reviewed by certiorari or controlled by mandamus, unless exercised arbitrarily or capriciously. A person with a legal interest in the matter in litigation may be allowed to intervene, provided the intervention will not unduly delay or prejudice the adjudication of the rights of the original parties and their rights may not be fully protected in a separate proceeding. A motion to intervene may be filed at any time before the rendition of judgment by the trial court.