GR L 23704; (July, 1972) (Digest)
G.R. No. L-23704 July 28, 1972
BENIGNA H. PINTACASI, petitioner, vs. THE COURT OF AGRARIAN RELATIONS and GRACIANO JAPSON, respondents.
FACTS
Petitioner Benigna H. Pintacasi, a widow, filed an ejectment suit against her tenant, respondent Graciano Japson, before the Court of Agrarian Relations (CAR). The complaint alleged that Japson killed petitioner’s husband, the landholder, and that this act created an atmosphere of tension and demoralization among the other tenants. Japson admitted the killing but pleaded self-defense, and the corresponding criminal case for murder was pending before the regular court at the time of the agrarian suit.
The CAR dismissed the complaint for ejectment as premature. It relied on the explicit language of Section 50(g) of the Agricultural Tenancy Act ( Republic Act No. 1199 ), which authorizes dispossession of a tenant upon “conviction by a competent court” of a crime against the landholder or a member of his immediate family. Since Japson was merely charged and not yet convicted, the CAR held the statutory ground for ejectment was not yet available, notwithstanding the admission of the killing.
ISSUE
Whether the Court of Agrarian Relations correctly dismissed the ejectment complaint for being premature, pending the final conviction of the tenant for the killing of the landholder.
RULING
The Supreme Court reversed the decision of the CAR. The legal logic proceeds from a recognition of a supervening event that rendered the appealed decision moot and academic. While the petition was pending before the Supreme Court, Graciano Japson was convicted by a competent court for the crime of homicide, and his sentence had become final and executory.
The Court acknowledged that, at the time the CAR rendered its decision, a strict and literal application of Section 50(g) of the Agricultural Tenancy Act was technically correct, as the required conviction was absent. The law’s clear text demanded application, not interpretation. However, the subsequent conviction removed the very impediment cited by the CAR. The final judgment of conviction supplied the missing element that matured the cause of action for ejectment under the law.
Consequently, the basis for the CAR’s dismissal—the prematurity of the action—ceased to exist. The decision under review lost its validity and was set aside. The Supreme Court ordered the case remanded to the CAR for the sole purpose of issuing the writ of execution for the ejectment of respondent Japson, his right to continue as a tenant having been extinguished by his final conviction for a crime against the landholder. The ruling effectuates the law’s intent without needing to reach the constitutional due process arguments tentatively raised by the petitioner regarding the law’s application during the pendency of the criminal case.