MARIA BUKID, MIGUEL CASTILLO AND MANUEL CARANDANG, PETITIONERS, VS. HON. ALBERTO A. REYES, JUDGE OF THE COURT OF AGRARIAN RELATIONS, BRANCH II, SEVENTH REGIONAL DISTRICT; CRISAN…

Bukid versus Reyes

The Case

This is a special civil action of certiorari and prohibition brought by Maria Bukid and her sons, Miguel Castillo and Manuel Carandang, against Judge Alberto Reyes of the Court of Agrarian Relations, Branch Two, Seventh Regional District, and against Crisanto Salazar and the spouses Laureano Macalintal and Irenea Acapio. The petitioners ask the Supreme Court to undo the agrarian court's refusal to let them intervene in a pending tenancy case between Salazar and the Macalintal spouses. The case matters because it fixes the standard for intervention in agrarian proceedings: a person whose share in the produce and whose right to remain on the land would be prejudiced by the judgment has an actual, direct and immediate interest that entitles him to intervene, and denying that intervention is grave abuse of discretion.

Procedural History

Crisanto Salazar filed a complaint in the Court of Agrarian Relations, Lipa City Branch, against the Macalintal spouses, docketed as CAR Case Number 1800. Maria Bukid and her sons sought to intervene, and upon the lower court's order they filed an intervention complaint on December 10, 1975. Salazar opposed the motion, while the Macalintal spouses manifested that they interposed no objection. The lower court denied the motion for intervention in a minute order dated February 20, 1976. The intervenors filed a motion for reconsideration and an amended complaint in intervention, but the court denied reconsideration in a minute order dated March 23, 1976, a copy of which was served on them on April 1, 1976. On April 12, 1976, they filed the present petition for certiorari and prohibition with the Supreme Court.

Facts

The Macalintal spouses owned two parcels of land in Barrio Maugat, Padre Garcia, Batangas. In 1957, or after Salazar married Macalintal's sister, Salazar became a tenant on their six-hectare parcel. When the spouses acquired a one-hectare coconut land in 1960, Salazar also became its tenant, and he planted coconut, coffee and mango trees and banana plants. Later, with the consent of the Macalintal spouses and at the request of his mother Maria Bukid, Salazar allowed Miguel Castillo to plant seasonal crops on the portion not planted to fruit-bearing trees. Manuel Carandang, another son of Maria Bukid, succeeded Castillo as tiller.

In 1972, when Salazar separated from his wife, he asked the Macalintal spouses to pay for the trees he had planted. The spouses did not honor their commitment. They dispossessed him of the land and asked Maria Bukid to administer the landholdings. Salazar then sued, praying that the spouses account for the produce and pay his share, or pay the value of the permanent trees, plus disturbance compensation and damages.

The Macalintal spouses answered that Salazar was their tenant only until 1967, when he surrendered or abandoned the land and moved to Quezon Province. It was then that Maria Bukid became their overseer and her two sons became their tenants. In February 1975, Salazar surreptitiously occupied the spouses' house on the land, and they filed an ejectment suit against him in the municipal court of Padre Garcia. Maria Bukid and her sons alleged that since 1967 they had been the overseer and tenants, respectively, and that Salazar forcibly entered the house and dislodged Maria Bukid. They prayed that Salazar and the Macalintal spouses be ordered to recognize Maria Bukid as overseer and her sons as tenants.

Issues

• Whether or not the Court of Agrarian Relations gravely abused its discretion in denying the motion for intervention of Maria Bukid and her sons.
• Whether or not the intervenors have an actual, material, direct and immediate interest in the subject matter of Salazar's action.
• Whether or not complete relief can be granted in Salazar's action without hearing the intervenors' side of the controversy.

Applicable Provisions

Section 155 of the Code of Agrarian Reforms, as cited in the decision, provides:

The proceedings in the Court of Agrarian Relations shall be governed by the Rules of Court.

This makes the Rules of Court on intervention the measure of the agrarian court's action, so the denial must be tested against those rules.

Section 2 of Rule 3 of the Rules of Court, as cited in the decision, provides:

Every action must be prosecuted in the name of the real party in interest.

The intervenors claim a direct stake in the landholding and its produce, which makes them real parties in interest as to the relief Salazar seeks.

Sections 7 and 8 of Rule 3, in relation to Rule 12 of the Rules of Court, as cited in the decision, govern intervention and provide the standard the Court applied:

A person having a legal interest in the matter in litigation may intervene.

The Court measured the petitioners' interest against this requirement and found it actual and material, not merely contingent.

Ruling

On the first issue, the Court held that the agrarian court gravely abused its discretion in denying the motion for intervention. The proceedings in the agrarian court are governed by the Rules of Court, and under those rules a person with a legal interest in the matter in litigation may intervene.

On the second issue, the Court found that the intervenors have such an interest. Salazar wants to take the place of Castillo and Carandang as tenants and to be restored to possession of the landholdings which, since 1967, have allegedly been under the control of the intervenors. Salazar's demand for his share of the produce during the time the land was in their possession, or alternatively for the price of the permanent trees, would adversely affect their own shares in the products already received and still to be received, as well as their rights, if any, to the plantings. Their interest is actual and material, direct and immediate, and not merely contingent and inchoate.

On the third issue, the Court held that complete relief cannot be granted in Salazar's action without hearing the intervenors' side, and that any adjudication in Salazar's favor would prejudice them. Their intervention would not unduly delay or prejudice the adjudication of the rights of Salazar and the Macalintal spouses. Admitting the intervention complaint would obviate duplicity of suits.

Doctrine

A Bar candidate should retain these rules. First, proceedings in the Court of Agrarian Relations are governed by the Rules of Court, so the rules on intervention apply in agrarian cases. Second, a person having a legal interest in the matter in litigation may intervene, and that interest must be actual and material, direct and immediate, not merely contingent and inchoate. Third, where a judgment would adversely affect an intervenor's share in the produce of the land or his right to the plantings thereon, complete relief cannot be granted without hearing him, and denying intervention is grave abuse of discretion. Fourth, intervention is the proper remedy to avoid duplicity of suits where the intervenor's claim is intertwined with the pending case.

Disposition

The Supreme Court granted the petition, set aside the agrarian court's order denying the motion for intervention, and directed that the intervention complaint of Maria Bukid, Miguel Castillo and Manuel Carandang be admitted, without costs.

Remember This

Memorize this line: a person whose share in the produce and whose right to the land would be prejudiced by the judgment has an actual, direct and immediate interest that entitles him to intervene, and refusing him is grave abuse of discretion. Examiners use this case to test intervention under the Rules of Court as applied to agrarian proceedings, and the distinction between a direct and immediate interest and one that is merely contingent and inchoate.