Mejares v. Reyes

G.R. No. 66555 (March 7, 1996)

Facts:

On April 21, 1978, Manuel Adarna purchased Cadastral Lot No. 7-B in Tulay, Minglanilla, Cebu, from Vidal Zafra, who had acquired it from Escolastico Canizares. The lot was originally approved for residential and agricultural purposes in 1956. Prior to Adarna's ownership, the petitioners, Leoncio Mejare and Epifania Larumbe, had occupied a portion of the lot and built their house there, with the previous owner's tolerance. After acquiring the property, Adarna initially allowed the petitioners to stay without rent, provided they would vacate when he needed the land.

In May 1979, Adarna notified the petitioners that he required the lot for his own use. When the petitioners refused to vacate, Adarna filed a criminal complaint against them for squatting under Presidential Decree No. 772, known as the Anti-Squatting Law. The Information charged the petitioners with unlawfully occupying the land against the will of the owner.

The trial court, after the prosecution rested its case, considered the petitioners to have waived their right to present evidence due to their failure to appear for the scheduled hearing. Consequently, on December 10, 1982, the court convicted the petitioners, imposing a fine and ordering them to remove their house from the property. The petitioners' motion for reconsideration was denied.

Legal Issues:

1. Whether the petitioners were criminally liable for squatting under P.D. 772 despite having initially occupied the land with the previous owner's consent.
2. Whether the Anti-Squatting Law applies to agricultural land located in a rural area.
3. Whether the court had jurisdiction to entertain the petition for certiorari.

Arguments:

• Petitioners' Arguments:

  • They contended that they did not occupy the land unlawfully, as they had the previous owner's consent to stay on the property.
  • They argued that the Anti-Squatting Law does not apply to agricultural lands, citing the case of People vs. Echavez, which stated that the law was intended for urban communities.
  • They claimed that the trial court's decision was rendered with grave abuse of discretion.

• Respondent's Arguments:

  • Adarna maintained that the petitioners occupied the land against his will after he demanded they vacate.
  • He argued that the Anti-Squatting Law applies regardless of the land's classification, as long as the elements of unlawful occupation are met.

Court's Decision and Legal Reasoning:

The Supreme Court ruled in favor of the petitioners, granting the petition for certiorari and setting aside the trial court's judgment of conviction. The Court reasoned as follows:

1. Jurisdiction: The Court affirmed its jurisdiction to entertain the petition, noting that certiorari could be an appropriate remedy in cases of grave abuse of discretion, even if it typically cannot substitute for a lost appeal.

2. Dispossession: The Court found that the second and third elements of the offense under P.D. 772 were not present. Adarna had initially consented to the petitioners' occupancy, which negated the claim that they occupied the land against his will. The Court emphasized that consent invalidated the assertion of unlawful occupation.

3. Applicability of the Anti-Squatting Law: The Court clarified that while the Anti-Squatting Law was primarily aimed at urban squatting, it could apply to agricultural land if the occupation was unlawful. However, in this case, since the petitioners had not occupied the land unlawfully, they could not be convicted under the law.

The Court concluded that the petitioners should be acquitted, emphasizing that the ruling did not address the legality of their possession but rather the propriety of their conviction.

Significant Legal Principles Established:

• Consent from the landowner negates claims of unlawful occupation under the Anti-Squatting Law.
• The applicability of P.D. 772 is not strictly limited to urban areas; however, the nature of the occupation must still meet the law's criteria for unlawful possession.
• The Supreme Court may exercise jurisdiction in certiorari cases to prevent miscarriage of justice, even when procedural rules suggest otherwise.