GR L 62063; (April, 1983) (Digest)

G.R. No. L-62063 April 28, 1983
NORBERTO GERONIMO and ANACLETO GERONIMO, petitioners, vs. COURT OF APPEALS, COURT OF AGRARIAN RELATIONS, and BELEN L. LUNA, respondents.

FACTS

The case originated from CAR Case No. 880, where the landowner, Joaquin Arambulo, sought the ejectment of Norberto and Anacleto Geronimo from several agricultural lots. The Court of Agrarian Relations (CAR) rendered a decision on June 26, 1979, finding that Norberto Geronimo had ceased to be a tenant in 1972 when he transferred possession to his father, Anacleto, without the landowner’s consent. The court declared Anacleto was never a tenant, and Norberto was merely a paid laborer on other lots. Consequently, the CAR ordered the petitioners to vacate the properties. This decision was affirmed in toto by the Court of Appeals on October 6, 1980, and subsequently, the Supreme Court denied the petitioners’ petition for review on certiorari (G.R. No. L-55461) on December 2, 1981, with a final denial of their motion for reconsideration on December 16, 1981.
Upon Arambulo’s death, he was substituted by his wife, Belen L. Luna. A writ of execution was issued on April 27, 1982. The petitioners filed an urgent motion to stay execution, arguing that ejectment could not proceed until the Ministry of Agrarian Reform issued the implementing rules and regulations for Presidential Decree No. 27. The CAR denied this motion on June 18, 1982. The petitioners then appealed this order to the Court of Appeals via a petition for review, which was dismissed on August 3, 1982, primarily for being filed out of time, as they failed to comply with the appeal period prescribed under Section 18 of P.D. No. 946.

ISSUE

The core issue is whether the petitioners, having been conclusively found not to be tenant-farmers, are entitled to a stay of execution of the ejectment order based on the prohibition under P.D. No. 316, which bars the ejectment of tenant-farmers pending the determination of rights under P.D. No. 27.

RULING

The Supreme Court denied the petition. The legal logic is straightforward and hinges on the final and conclusive factual determination that the petitioners are not tenant-farmers. P.D. No. 316 explicitly prohibits the ejectment of a “tenant-farmer in agricultural lands primarily devoted to rice and corn” until the rights of the parties are determined under P.D. No. 27. This protective mantle, however, applies only to individuals who qualify as tenant-farmers under the law. The CAR, in a decision that became final and executory after affirmance by both the Court of Appeals and the Supreme Court, definitively ruled that Norberto Geronimo had relinquished his tenancy status and that Anacleto Geronimo was never a tenant. Therefore, the petitioners fall outside the scope of P.D. No. 316’s protection. Since they are not tenants, the legal prohibition against ejectment does not apply to them, and the landowner is lawfully entitled to possession. The Court also noted the procedural flaw in their appeal to the Court of Appeals regarding the order denying the stay of execution, but the substantive ruling on their non-tenancy status was dispositive. The execution of the final judgment could thus proceed lawfully.