GR L 45647; (September, 1987) (Digest)
G.R. No. L-45647 August 21, 1987
MANUEL Q. CABALLERO and LELITA A. CABALLERO, petitioners, vs. HON. FEDERICO B. ALFONSO, JR., as Judge, Branch III, Court of First Instance of Misamis Oriental, HON. CONRADO ESTRELLA, as Secretary of the Department of Agrarian Reform, FERNANDO ESCONDE, GREGORIO BAKEREL, CESAR NAVARRO, AND FRANK RODRIGUEZ, respondents.
FACTS
Petitioners, spouses Manuel and Lelita Caballero, filed a petition for injunction with damages in the Court of First Instance of Misamis Oriental. They alleged that private respondents, including Fernando Esconde, Gregorio Bakerel, and Cesar Navarro, entered their coconut land and illegally harvested the fruits without consent. The petitioners claimed ownership and sought damages. In their answer, the private respondents admitted the petitioners’ ownership but asserted that Esconde, Navarro, and Bakerel were tenants on the land. They contended the case was agrarian in nature and thus within the exclusive jurisdiction of the Court of Agrarian Relations.
The respondent judge initially issued a temporary restraining order. Subsequently, upon a motion for reconsideration from the private respondents, the judge issued an order dated January 10, 1977, suspending the proceedings. This suspension was in accordance with Presidential Decree No. 1038, which required referral to the Secretary of Agrarian Reform for a preliminary determination of the landlord-tenant relationship before a court could proceed with an ejectment case or any case designed to harass or remove a tenant. The petitioners’ motion for reconsideration of this suspension order was denied, prompting this petition.
ISSUE
Whether the respondent judge committed grave abuse of discretion in suspending the court proceedings and ordering referral to the Secretary of Agrarian Reform under P.D. No. 1038.
RULING
The Supreme Court granted the petition. The Court upheld the constitutionality of P.D. No. 1038, ruling that the requirement for a preliminary determination by the Secretary of Agrarian Reform was a valid exercise of police power intended to protect tenants from vexatious and oppressive litigation. The referral mechanism did not constitute an undue encroachment on judicial independence, as the court retained ultimate authority to confirm, reverse, or modify the Secretary’s preliminary determination after due hearing.
However, the Court found that under the circumstances of this case, the continued suspension of proceedings was no longer justified. The challenged order was issued on January 10, 1977, and a decade had elapsed without the Secretary of Agrarian Reform completing the required preliminary determination. The Court emphasized that the Secretary had been given more than sufficient time to act. Consequently, the respondent judge was directed to set aside the suspension order and to proceed with hearing and deciding the case expeditiously, without further waiting for the certification from the Secretary of Agrarian Reform. The delay had rendered the suspension unreasonable.