G.R. No. L-14651; February 29, 1960
HACIENDA SAPANG PALAY TENANTS’ LEAGUE, INC. and DOMINADOR GUEVAN, petitioners, vs. NICASIO YATCO, in his capacity as Judge of the Court of First Instance of Rizal, 7th Judicial District, Branch V, Quezon City, and PHILIPPINE SUBURBAN DEVELOPMENT CORPORATION, respondents.

FACTS

The Philippine Suburban Development Corporation (the Corporation) filed a complaint for specific performance and damages (Civil Case No. Q-3332) against the Chairman-General Manager and Members of the Board of the People’s Homesite & Housing Corporation (PHHC). The Corporation sought to compel the PHHC to execute a deed of sale and pay for one-half of Hacienda de Sapang-Palay in Bulacan, pursuant to a perfected contract. The Hacienda Sapang-Palay Tenants League, Inc. (the League), a corporation of tenant-farmers on the hacienda, together with its president, filed a motion to intervene. They alleged an interest in the success of the PHHC officials in resisting the sale because if the PHHC acquired the land for housing, the tenants would be dispossessed. They further claimed a legal right in the property under Republic Act No. 1400 (the Land Reform Act of 1955), as they had petitioned the Land Tenure Administration (LTA) to purchase the land for resale to them. The Corporation opposed the motion. The respondent Judge denied the motion for intervention, ruling that the League’s interest was merely contingent or expectant and did not constitute a sufficient legal interest under Rule 13 of the Rules of Court. The League’s motion for reconsideration was also denied, prompting this petition for mandamus and/or certiorari.

ISSUE

Whether the tenant-farmers represented by the League have a legal interest in the property or in the success of any party to the case, sufficient to justify their intervention under Rule 13 of the Rules of Court.

RULING

The Supreme Court denied the petition and affirmed the order of the lower court. The Court held that the League’s claimed interest was merely contingent and expectant, not actual, direct, material, and immediate as required for intervention. The petitioners based their claim on Section 20 of Republic Act No. 1400, which prohibits alienation of land upon the filing of a petition with the LTA. However, the Court explained that under Sections 12 and 16 of the same Act, the mere filing of a petition is insufficient to bind the landowner or create a vested right for the tenants. The LTA must first take positive steps, such as determining the land’s suitability, conducting investigations, and fixing dates for negotiation, before the state’s power of eminent domain can be exercised in favor of the tenants. Until such steps are taken, the landowner’s right of dominion, including the right to alienate the property, remains unaffected. Citing a precedent interpreting a similar provision in Republic Act No. 1162, the Court ruled that the prohibition against alienation (or ejectment) applies only when expropriation has actually commenced, i.e., when the LTA has taken the steps outlined in the law. Since the LTA had not taken such steps, the petitioners’ right to acquire the land was only in expectancy. Their remedy was to urge the LTA to take immediate action on their petition. Without an amended petition showing that the statutory steps had been taken or that the PHHC lacked the charter power to acquire the land, they had no standing to intervene.