G.R. No. L-21281 May 24, 1967
EDILBERTO BALANE, GASPAR FRANCISCO, PIO MAGDAMIT, PABLO VALEROS, FELIX ELNAR, ARMANDO GALERO, JOVITO PALMA, MODESTO SALEN, ALBERTO VALEROS, and LUCIANO VALEROS, petitioners, vs. PASTOR L. DE GUZMAN, as Presiding Judge of the Court of Agrarian Relations, 6th Regional District, and FRANCISCO QUINTELA, respondents.

FACTS

Respondent Francisco Quintela filed an amended petition with the Court of Agrarian Relations, alleging he was the tenant-overseer of lands owned by Oliva Bustos in Paracale, Camarines Norte, that he planted coconut trees thereon, and that he had been unlawfully ejected. He prayed for reinstatement and compensation for the improvements. The landowners, Oliva Bustos and Jesus Ma. Bernarte, filed an answer denying Quintela’s material allegations. Two days later, the petitioners filed a motion for intervention with an attached answer, alleging they were the only bona fide tenants on the land and that they were the ones who planted the coconut trees claimed by Quintela. They prayed for the dismissal of the amended petition and an award of attorney’s fees. Quintela opposed the motion. Respondent Judge denied the motion for intervention, ruling that the petitioners showed no inchoate interest in the subject matter of the litigation and had not complied with procedural requirements for intervention. Petitioners’ motion for reconsideration was denied, prompting them to file this petition for mandamus to compel the judge to allow their intervention.

ISSUE

Whether the respondent Judge acted with grave abuse of discretion amounting to lack or excess of jurisdiction in denying the petitioners’ motion for intervention, warranting the issuance of a writ of mandamus.

RULING

The Supreme Court granted the writ of mandamus. While mandamus generally cannot control discretion and the allowance of intervention rests in the court’s sound discretion, such discretion is not unlimited. The Rules require the court to consider whether intervention will unduly delay or prejudice the adjudication of the rights of the original parties and whether the intervenor’s rights may be fully protected in a separate proceeding. A denial of intervention contrary to these considerations may be arbitrary and correctible by mandamus if an ordinary appeal is not an adequate and speedy remedy. In this case, allowing intervention would not have caused undue delay, as the motion was filed before trial and shortly after the defendants’ answer. Furthermore, the petitioners’ rights would not be fully protected in a separate proceeding. A decision in favor of Quintela declaring him the tenant entitled to compensation would directly and injuriously affect the petitioners’ material interest as the alleged bona fide tenants who planted the trees. This would violate due process. Conversely, a ruling for Quintela while saving the petitioners’ claim for a separate proceeding would subject the landowners to the risk of dual liability, having to recognize both parties as tenants and pay compensation twice for the same improvements. The respondent Judge should have brushed aside technicalities and allowed the intervention to avoid needless delay and properly resolve all conflicting interests. The writ was granted, and the respondent Judge was ordered to allow the petitioners’ intervention. Costs were imposed on respondent Francisco Quintela.