Bayog v. Natino
G.R. No. 118691 (July 5, 1996)
Facts:
On June 16, 1973, Alejandro Bayog (BAYOG) and Alberto Magdato (MAGDATO) entered into an Agricultural Leasehold Contract for a 0.8-hectare lot in Centro Pojo, Bugasong, Antique, with BAYOG as the landowner and MAGDATO as the tenant. The contract commenced in the crop year 1975-1976 and stipulated that matters not covered would be governed by Republic Act No. 3344, as amended. On April 19, 1983, President Ferdinand E. Marcos issued a Certificate of Agricultural Leasehold to MAGDATO, affirming his rights as a tenant, including protection against eviction without court authorization.
In September 1990, BAYOG executed a Deed of Equitable Mortgage in favor of Santiago Pesayco, covering several parcels of land. On October 19, 1992, BAYOG requested MAGDATO to remove his house from the land, claiming it obstructed cultivation by Jorge Pesayco, Jr., who was leasing the land from Santiago Pesayco. MAGDATO did not comply, leading BAYOG and Jorge Pesayco, Jr. to file an ejectment complaint against him on November 26, 1992, which was docketed as Civil Case No. 262 in the Third Municipal Circuit Trial Court (MCTC) of Patnongon-Bugasong-Valderama, Antique.
The MCTC issued an order on December 15, 1992, directing the issuance of summons. MAGDATO filed his answer late, on January 25, 1993, admitting BAYOG's ownership but asserting his rights as a tenant and claiming the court lacked jurisdiction due to the agrarian dispute. On September 20, 1993, the MCTC ruled that MAGDATO's late answer could not be considered, leading to a judgment in favor of BAYOG, ordering MAGDATO's eviction and the demolition of his house.
MAGDATO's house was demolished on January 24, 1994, following an order of execution issued by the MCTC. On February 9, 1994, MAGDATO filed a petition for relief from judgment with the Regional Trial Court (RTC), alleging that his late filing was due to illness and illiteracy. He sought to set aside the MCTC judgment and claimed he had strong evidence to support his tenancy rights.
BAYOG filed a motion to dismiss the RTC petition, arguing lack of jurisdiction, failure to state a cause of action, and that the petition was filed out of time. The RTC denied BAYOG's motions to dismiss and set aside the MCTC judgment, remanding the case for proper disposition.
Legal Issues:
- Whether the RTC had jurisdiction to entertain the petition for relief from judgment despite the prohibition under the Revised Rule on Summary Procedure.
- Whether MAGDATO's late filing of his answer in the ejectment case should have been considered by the MCTC.
- Whether the MCTC had jurisdiction over the ejectment case given the agrarian relationship between the parties.
Arguments:
Petitioners (BAYOG and Pesayco):
- The RTC lacked jurisdiction to entertain the petition for relief from judgment as it was a prohibited pleading under the Revised Rule on Summary Procedure.
- MAGDATO's answer was filed out of time and should not have been considered, rendering the MCTC's judgment valid and final.
- The petition for relief was filed out of time and did not state a valid cause of action.
Respondent (MAGDATO):
- The RTC had jurisdiction as the prohibition against petitions for relief did not apply to Regional Trial Courts.
- The MCTC should have considered MAGDATO's late answer, which raised the issue of jurisdiction based on the agrarian relationship.
- The petition for relief was timely filed, and MAGDATO had valid defenses that warranted a new trial.
Court's Decision and Legal Reasoning:
The Supreme Court dismissed the petition for certiorari filed by BAYOG and Pesayco, affirming the RTC's order setting aside the MCTC's judgment. The Court held that:
- The RTC correctly determined that the petition for relief from judgment was not prohibited under the Revised Rule on Summary Procedure, as this rule applies to lower courts and not to the RTC.
- The MCTC erred in disregarding MAGDATO's late answer, which raised a valid defense regarding the agrarian relationship and jurisdiction. The MCTC should have heard the evidence to determine its jurisdiction.
- The MCTC's orders for removal and demolition before the judgment became final were oppressive and violated procedural rules, warranting the RTC's intervention.
The Court emphasized the need to protect the rights of agricultural tenants and noted that MAGDATO's circumstances warranted relief from the judgment. The Court also highlighted the importance of ensuring that parties are afforded due process, particularly in cases involving agrarian disputes.
Significant Legal Principles Established:
- The prohibition against petitions for relief from judgment under the Revised Rule on Summary Procedure does not apply to Regional Trial Courts.
- A late answer asserting a defense of lack of jurisdiction based on an agrarian relationship should be considered by the court.
- Courts must ensure that procedural rules are followed to prevent unjust eviction and protect the rights of tenants.