G.R. No. L-11023 December 14, 1956
Alipio Sicat, et al., petitioners, vs. Hon. Pastor P. Reyes, etc., et al., respondents.
FACTS
Arcadio Lagman was a tenant of landlord Francisco Liongson from 1932 to 1951 on three parcels of riceland in Bacolor, Pampanga. In May 1951, due to Lagman’s failure to pay agreed rentals, Liongson dispossessed him of the land and gave it to Alipio Sicat, who worked the land thereafter. On September 1, 1952, Lagman filed a petition with the Court of Industrial Relations against Liongson (Tenancy Case No. 4375-R), praying for reinstatement as tenant, alleging his dispossession was without just cause. The case was amicably settled by an agreement between Lagman and Liongson, stipulating that Lagman be reinstated beginning the 1956-1957 crop year and that the present tenant, Alipio Sicat, should vacate the land. The court approved this agreement on January 23, 1956, ordering it to be given effect as a decision on the merits. On July 6, 1956, the order having become final, the court ordered its execution, and the sheriff ejected Sicat from the land on the same date. Sicat filed a motion for reconsideration, contending the ejectment order and writ of execution were illegal as to him because he was not given his day in court. Upon denial of his motion, Sicat interposed the present petition for certiorari.
ISSUE
Whether the order of ejectment and the writ of execution issued by the Court of Industrial Relations against Alipio Sicat are valid and binding, considering he was not a party to the tenancy case between Lagman and Liongson.
RULING
The Supreme Court granted the petition. The order dated January 23, 1956, and the writ of execution of July 6, 1956, are null and void, having been issued in excess of jurisdiction. The amicable agreement between Lagman and Liongson, which included a stipulation for Sicat to vacate the land, cannot be binding and conclusive upon Sicat, who was not a party to the case. The Court emphasized that no person shall be deprived of life, liberty, or property without due process of law, which contemplates notice and opportunity to be heard before judgment is rendered affecting one’s person or property. Since Sicat was not given his day in court, the orders were declared null and void. The writ of injunction issued by the Supreme Court was made permanent.
