G.R. No. L-8174 and L-8280-8286 October 8, 1955
AGAPITO ALAJAR, ET AL., petitioners-appellants, vs. HON. COURT OF INDUSTRIAL RELATIONS and CIRILO P. BAYLOSIS, ET AL., respondents-appellees. BUREAU OF LANDS, intervenor.

FACTS

This is a petition for certiorari to review a decision of the Court of Industrial Relations (CIR) in eight consolidated tenancy cases (Nos. 871-R to 878-R). The CIR ordered the division of the palay harvest for the crop year 1950-1951 between the petitioners (tenants) and the respondents (landlords) on a 70-30 ratio in favor of the tenants. The CIR based the quantity of the harvest for each landholding on estimates of the number of cavans produced, as listed in its decision. The petitioners claim the CIR committed grave abuse of discretion by estimating the harvest in cavans instead of cans, allegedly in complete disregard of a decision from the Court of First Instance of Batangas in Expropriation Proceedings No. 84 and a subsequent Supreme Court decision in G.R. L-6191. The landholdings involved were part of tracts the government sought to expropriate in those proceedings for resale to tenants. The Batangas court initially ordered the transfer of the lands to the Bureau of Lands, but the Supreme Court later dismissed the expropriation proceedings. The tenancy cases arose before the expropriation proceedings were filed. The CIR found that the tenants harvested their palay for 1950-1951 before the transfer of the landholdings to the Bureau of Lands was ordered in the expropriation case, and thus proceeded to order the division of that harvest.

ISSUE

Whether the Court of Industrial Relations acted with grave abuse of discretion in issuing its decision ordering the division of the harvest based on cavan estimates, allegedly in disregard of the decisions in Expropriation Proceedings No. 84 and G.R. L-6191.

RULING

The Supreme Court dismissed the petition for certiorari. The petition was patently without merit and insufficient in form and substance to justify the writ. The petitioners charged abuse of discretion for disregarding prior decisions but failed to attach those decisions to the petition or point out which specific portions were violated. The Supreme Court examined the referenced decisions and found that neither the Supreme Court’s decision in G.R. L-6191 nor the Batangas court’s decision in Expropriation Proceedings No. 84 contained any pronouncements regarding harvests or their division. The Supreme Court agreed with the respondents that the proceedings were instituted merely to further delay the division of the harvest, which had been pending litigation since 1950. Costs were awarded against the petitioners.