G.R. No. L-49360 December 14, 1979
FILEMON DAVID, petitioner, vs. HON. GREGORIO U. AQUILIZAN, FELOMENO JUGAR and RICARDO JUGAR, respondents.

FACTS

Private respondents Felomeno and Ricardo Jugar filed a petition for reinstatement before the Court of Agrarian Relations (CAR), alleging they were share tenants on petitioner Filemon David’s corn landholding. They claimed David unlawfully ejected them in 1973. David countered that the Jugars were not unlawfully ejected but had voluntarily surrendered their landholdings, with Ricardo resigning as his tractor driver due to illness and later working elsewhere, and Felomeno resuming his faith-healing occupation and working on his father’s farm. A prior investigation by the Department of Agrarian Reform (DAR) Hearing Officer resulted in a report dated April 12, 1976, which found no unlawful ejectment and recommended dropping the case, noting the Jugars’ own admissions that the land was only “borrowed” and their subsequent alternative employments.
On June 29, 1978, respondent Judge Gregorio U. Aquilizan issued an order directing the DAR to place the land under Operation Land Transfer, citing a Court of Appeals ruling. Subsequently, on September 29, 1978, without conducting any further hearing or receiving evidence, the respondent judge rendered a decision in favor of the Jugars, declaring them tenants entitled to coverage under Presidential Decree No. 27 and ordering their reinstatement. David filed this petition for certiorari to annul this decision.

ISSUE

Whether the respondent judge committed grave abuse of discretion amounting to lack or excess of jurisdiction by rendering a decision without conducting a trial or hearing, thereby violating petitioner’s right to due process.

RULING

Yes. The Supreme Court granted the petition and set aside the challenged decision and order. The Court emphasized that a judicial decision rendered without a hearing, where the parties are not given an opportunity to present evidence and be heard, is a patent nullity for violating constitutional due process. Due process requires that a party be afforded a fair and reasonable opportunity to explain his side. The respondent judge’s act of deciding the case based solely on the pleadings and the earlier DAR report, without conducting any trial, was a denial of this fundamental right.
The legal logic is clear: a judgment rendered in violation of due process is void ab initio. It creates no rights and imposes no duties. It is as if it never existed in the eyes of the law. Consequently, such a void judgment does not attain finality and can be assailed at any time, even after the period for appeal has lapsed. The Court found that the respondent judge’s summary disposition, without the requisite hearing, constituted grave abuse of discretion. The case was remanded to the court of origin with instructions to conduct appropriate proceedings, thereby ensuring that the petitioner’s right to due process is respected in the adjudication of the tenancy dispute.