FAUSTINO RONCESVALLES, PETITIONER, VS. LUIS PATOLA AND HONORABLE JUDGE VALERIANO A. DEL VALLE, COURT OF AGRARIAN RELATIONS, NINTH REGIONAL DISTRICT, BRANCH II, RESPONDENTS.

Roncesvalles versus Patola

The Case

This is a petition for certiorari, prohibition, and mandamus, with a prayer for a writ of preliminary injunction, brought by Faustino Roncesvalles against Luis Patola and the presiding judge of the Court of Agrarian Relations. The petitioner was a tenant whom the agrarian court had ordered temporarily dispossessed through an interlocutory order, without any hearing on the merits of the ejectment action. The case matters because it asks a question every agrarian law examinee should recognize: may a tenant be thrown off the land by an interlocutory order before the merits of the ejectment suit are heard? The Supreme Court gave the petition due course precisely because of the significance of that legal question, though the case would ultimately end without a ruling on the merits.

Procedural History

The action began in the Court of Agrarian Relations, Ninth Regional District, Branch Two, where Luis Patola sought the ejectment of his tenant Faustino Roncesvalles. The agrarian court issued an interlocutory order placing the tenant in temporary dispossession, without conducting a hearing on the merits. Roncesvalles then went directly to the Supreme Court by a petition for certiorari, prohibition, and mandamus with a prayer for a writ of preliminary injunction, and the Court gave the petition due course. After considerable time passed without any decision on the merits below, the Supreme Court required the parties to manifest whether the petition had become moot and academic. Counsel for the petitioner never filed the required manifestation, asking only for time to verify his records and then falling silent. Private respondent Patola, however, manifested that the matter had been settled amicably and that the pending case in the lower court had been dismissed. The Court then acted on that information and terminated the case.

Facts

Faustino Roncesvalles was a tenant of Luis Patola. Patola filed an action for ejectment against him in the Court of Agrarian Relations. In that action, the agrarian court issued an interlocutory order that had the effect of dispossessing Roncesvalles from the landholding, and it did so without any hearing on the merits of the ejectment case.

Patola defended the order on the ground that temporary dispossession was the proper remedial measure, because the tenant, notwithstanding his admission of ownership in Patola, had persistently refused to deliver the latter's share of the harvest. On that view, the agrarian court, in the exercise of sound discretion, could issue the order following one of the rules under the tenancy law then applicable.

While the petition was pending, the parties settled the matter amicably and the ejectment case in the lower court was dismissed. The Supreme Court noted that under later tenancy legislation, culminating in Presidential Decree Number 27, a bona fide tenant would have his rights fully respected, so that the legal issue posed had lost its significance.

Issues

• Whether or not, in an action for ejectment of a tenant, the tenant may be dispossessed by an interlocutory order without any hearing on the merits.
• Whether or not the petition had become moot and academic by reason of the amicable settlement of the parties and the dismissal of the pending case in the lower court.

Applicable Provisions

The decision refers to the tenancy law then applicable, Republic Act Number 1267, as the source of the rule under which the agrarian court issued the interlocutory order; the decision does not quote its text, so no verbatim provision from it can be reproduced here.

The decision likewise refers to Presidential Decree Number 27 as the later tenancy legislation, whose validity was sustained in Gonzalez versus Estrella; its text is not quoted in the decision either.

Ruling

On the first issue, the Court did not reach a merits ruling. It had given the petition due course because of the significance of the question whether a tenant could be dispossessed by an interlocutory order without a hearing on the merits, but the case was overtaken by events. The Court observed that the legal issue posed is no longer of significance, because under Presidential Decree Number 27 a tenant who is bona fide would have his rights fully respected.

On the second issue, the Court resolved the petition on mootness. After requiring the parties to manifest whether the petition had become moot and academic, and after receiving no further communication from counsel for the petitioner, the Court acted on the information furnished by counsel for private respondent that the matter had been settled amicably and the pending case in the lower court dismissed. The Court held that the case could thus be terminated, and it dismissed the petition for having become moot and academic.

Doctrine

First, a tenant in an ejectment action before the Court of Agrarian Relations may, under the tenancy law then applicable, be placed in temporary dispossession by interlocutory order where the agrarian court exercises sound discretion, as where the tenant admits the owner's ownership yet persistently refuses to deliver the owner's share of the harvest. That was the private respondent's contention, which the Court did not have to pass upon.

Second, and this is the rule the case actually stands for, a petition that assails the validity of an interlocutory order becomes moot and academic when the parties have settled the matter amicably and the case below has been dismissed. Courts will not resolve a legal question, however significant, once no live controversy remains and later legislation, such as Presidential Decree Number 27, fully protects the rights of a bona fide tenant.

Disposition

The petition was dismissed for having become moot and academic, without costs; private respondent Patola prevailed because the amicable settlement and the dismissal of the ejectment case left nothing for the Court to resolve.

Remember This

Memorize the line that the petition was dismissed for having become moot and academic after the parties settled amicably and the case below was dismissed. Examiners use this case to test mootness in special civil actions and to frame the agrarian law question of temporary dispossession of a tenant by interlocutory order without a hearing on the merits.