G.R. No. L-12335 November 29, 1968
CANUTO PAGDANGANAN, petitioner, vs. COURT OF AGRARIAN RELATIONS, 2nd District, Br. I, Cabanatuan City. ESTEBAN BALIGAD, ET AL., respondents.

FACTS

In Tenancy Case No. 1248-NE, the Court of Agrarian Relations (CAR) rendered a decision on October 5, 1956, ordering the ejectment of tenants Esteban Baligad and eight others from the land of landowner Canuto Pagdanganan in Guimba, Nueva Ecija. This judgment became final. On March 18, 1957, the CAR, upon motion, decreed its execution. However, on March 25, 1957, the tenants moved to stay the execution, alleging that in December 1955, a majority of the tenants in Hacienda Ilagan (where the landholdings were located) filed a petition with the Land Tenure Administration for the government’s acquisition of the hacienda under Republic Act No. 1400 (Land Reform Act of 1955). Acting on this motion and citing Section 20 of Republic Act 1400, the CAR, by its Resolution of April 15, 1957, quashed the writ of execution. Later, upon a motion for reconsideration, the court qualified its resolution, stating that if the Land Tenure Administration took no definite steps towards acquisition within three months, the court would be free to take proper action. Pagdanganan’s opposition and motion for reconsideration, asserting the court’s lack of jurisdiction because its decision had become final and executory, were denied. Consequently, Pagdanganan instituted this special civil action for mandamus and certiorari.

ISSUE

The primary issue is the proper interpretation of Section 20 of the Land Reform Act of 1955, specifically: (1) whether it applies where a “petition” for expropriation has been filed only with the Land Tenure Administration and not in court; (2) whether the CAR has the power to cancel the execution of a final decision based on such a petition; and (3) whether Section 20 applies when the court is advised of the petition for expropriation after the judgment in the ejectment proceedings has become final and executory.

RULING

The Supreme Court ruled in favor of the petitioner, Canuto Pagdanganan.
1. On the first proposition, the Court held that the petition contemplated in Section 20 is the petition of the tenants submitted to the Land Tenure Administration, as referred to in Sections 12 and 16 of the Act, and not an expropriation proceeding filed in court. However, the Court noted that the certification presented only stated that Hacienda Ilagan was “subject to a petition led by the supposed tenants and/or occupants,” not that it was filed by “a majority of the tenants” as strictly required by Sections 12 and 16. Those invoking a special privilege must comply strictly with the law’s provisions.
2. On the second and third propositions, the Court held that it was improper for the CAR to cancel the order of execution. The Court construed Section 20, which prohibits the institution or prosecution of ejectment proceedings until it is certain the land will not be acquired by the Administration. The Court reasoned that the section directs that no ejectment proceedings “shall be instituted or prosecuted” (i.e., prosecuted to judgment), but it does not direct that no final judgment shall be executed. The law intended to favor bona fide tenants or occupants lawfully in possession. Once an adverse judgment in ejectment proceedings becomes final, the tenants automatically lose their standing as bona fide occupants and fall beyond the scope of the Act’s benevolent provisions. Therefore, Section 20 could not be interpreted to cover the execution of a final judgment.
The Supreme Court annulled the CAR’s resolution of April 15, 1957, and directed the respondent court to execute its final decision of October 5, 1956.