Dejuras v. Villa
REITERATIONFacts
The Antecedents: Eutiquio Dejuras, predecessor-in-interest of petitioner Froilan Dejuras, filed a complaint for redemption of a 19,570 square meter parcel of land, Lot No. 1383-B, located in Sta. Rosa, Laguna. Eutiquio claimed to be a legitimate tenant/leaseholder for 50 years and asserted his right to the first option to buy the property under Republic Act No. 3844. The land was part of a larger property registered in the name of SM Prime Holdings, Inc. (SMPHI). The original owners, spouses Luis and Conchita Delfino, had donated the property to their son, Anthony Delfino, who subsequently sold it to Artemio Alon, without Eutiquio's knowledge. Procedural History: The Provincial Agrarian Reform Adjudicator (PARAD) initially dismissed Eutiquio's complaint, finding him to be a civil law lessee, not an agricultural leaseholder. The Department of Agrarian Reform Adjudication Board (DARAB) reversed this decision, deeming Eutiquio an agricultural lessee entitled to redemption. However, upon reconsideration, the DARAB reinstated the PARAD's decision. While Eutiquio's motion for reconsideration was pending, an Exemption Order was issued by the DAR exempting the lot from agrarian reform coverage, leading to a deed of absolute sale in favor of SMPHI. Subsequently, Eutiquio's successor-in-interest, Froilan Dejuras, filed a Petition for Coverage and a Petition for Revocation of Exemption Order. The DAR Regional Director denied the Petition for Coverage and lifted the cease-and-desist order. An appeal was lodged with the DAR Secretary, along with a motion for injunctive relief. Despite multiple motions, no prompt resolution was forthcoming. Eutiquio's successor, Florencio Dejuras, then filed a Petition for Mandamus with the Court of Appeals, seeking to compel the DARAB to resolve the pending motion for reconsideration and the DAR Secretary to grant the injunctive relief. The Petition: Petitioner Froilan Dejuras filed a petition for review under Rule 45 of the Rules of Court, assailing the Court of Appeals' decision that dismissed his petition for mandamus. The Court of Appeals had denied due course to the mandamus petition, citing that the DAR had already acted on the injunctive relief motion and the DARAB had resolved the motion for reconsideration, rendering the issue moot. The Court of Appeals also noted that mandamus is not available to compel the exercise of discretionary duties. Petitioner argued that the Court of Appeals erred in not considering the initial cease-and-desist order and that the subsequent actions undermined the Petition for Redemption. He further contended that the DAR and DARAB exceeded their authority and committed grave abuse of discretion in issuing their respective orders and resolutions. Petitioner sought the reversal of the Court of Appeals' decision to compel the DAR to issue an injunction and for SMPHI to be enjoined from further acts of ownership over the disputed property.
Issue(s)
Whether the Court of Appeals erred in declining to issue a writ of mandamus to compel the DAR Secretary and the DARAB to grant injunctive relief and resolve the pending motion for reconsideration.
Ruling
The Supreme Court denied the petition and affirmed the Decision of the Court of Appeals, holding that the grant of injunctive relief is discretionary and not compellable by mandamus, and that the issues raised were rendered moot and academic by subsequent resolutions from the DAR and DARAB.
Ratio Decidendi
On Issue 1: The Court ruled that the Court of Appeals correctly declined to issue the writ of mandamus because the acts sought to be compelled were discretionary, not ministerial. Mandamus is a remedy used to compel the performance of a ministerial duty where the law leaves no room for the exercise of judgment. However, as established in Valley Trading Co., Inc. v. Court of First Instance of Isabela, the issuance of a writ of preliminary injunction or a cease-and-desist order is an extraordinary remedy addressed to the sound discretion of the issuing authority. Such discretion is based on the determination of whether a clear and positive right exists that requires protection, which is a judgment call that cannot be dictated via mandamus. Additionally, the Court noted that the petition had become moot and academic because the public respondents eventually acted on the pending applications. The DAR denied the motion for injunctive relief on February 23, 2005, and the DARAB resolved the 1999 motion for reconsideration on April 20, 2005. Since the primary objective of the mandamus petition—to compel the respondents to act—was already fulfilled, there was no longer a justiciable controversy. The Court emphasized that it will not decide moot cases where a declaration would be of no practical value or use to the parties.
Main Doctrine
A writ of mandamus generally lies to compel the performance of a ministerial duty, but not the performance of an official act or duty which necessarily involves the exercise of judgment or discretion. While mandamus may be available to compel action when refused in matters involving judgment and discretion, it cannot direct the exercise of judgment in a particular manner, except in cases of gross abuse of discretion, manifest injustice, or palpable excess of authority. The grant of injunctive relief is discretionary and not compellable by mandamus unless there is a clear legal right that needs protection and the acts complained of are violative of such right.