G.R. No. 146540 ; July 14, 2004
HEIRS OF GERONIMO RESTRIVERA, ET AL., petitioners, vs. SALVADOR DE GUZMAN, ET AL., AS HEIRS OF THE LATE PEDRO ERMITAÑO AND TRICOM DEVELOPMENT CORPORATION, respondents.

FACTS

Petitioners, claiming to be agricultural tenants, filed a complaint for maintenance of peaceful possession against the heirs of the landowner, Pedro Ermitaño. The Provincial Agrarian Reform Adjudicator (PARAD) ruled they were not bona fide tenants and ordered them to vacate. On appeal, the Department of Agrarian Reform Adjudication Board (DARAB) initially reversed the PARAD in a Decision dated October 5, 1998, declaring petitioners as bona fide tenants.
During the pendency of the appeal, respondent Tricom Development Corporation (TRICOM) moved to intervene, claiming it had purchased the land. The DARAB first denied but later granted TRICOM’s motion via a Resolution dated March 4, 1999, which also held the effectivity of its October 5, 1998 Decision in abeyance. Petitioners moved for execution, arguing the October 1998 Decision had become final. The DARAB subsequently rendered a modified Joint Decision on December 27, 1999, withdrawing its earlier ruling and ordering petitioners to vacate in favor of TRICOM.

ISSUE

Whether the Court of Appeals erred in affirming the DARAB’s acts of allowing TRICOM’s intervention and modifying its allegedly final and executory Decision of October 5, 1998.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic is anchored on the nature of intervention and the authority of a quasi-judicial body to amend its decisions before finality. TRICOM’s motion for intervention was filed before the DARAB rendered its October 5, 1998 Decision. Intervention is allowed when a party has a legal interest in the matter in litigation. TRICOM, as an alleged purchaser, had a direct interest in the land subject of the tenancy dispute.
Crucially, the DARAB’s March 4, 1999 Resolution, which granted the intervention and held its earlier Decision in abeyance, was issued before that Decision attained finality. A judgment does not become final and executory until after the lapse of the period to appeal. By holding its Decision in abeyance and later allowing intervention to consider new evidence (including land classification), the DARAB acted within its jurisdiction to ensure all substantive rights were fully ascertained. The subsequent modified Decision was therefore a valid exercise of its adjudicatory power to harmonize its judgment with justice and the evidence presented by the intervenor. No grave abuse of discretion attended these proceedings.