Reyes vs.

CA
November 26, 1992
GR #: 96492

Facts:

Reyes, Parayao & Mananghaya are Brgy Officials in the barangay where the subject land
was located and they were named co-defendants together with the landlord in the
dispossession of the plaintiff from her tenanted land.

Mendoza (landlord) is the son of the original owner of the subjected land which is
agricultural in nature, whilst plaintiff delos Reyes succeeded her father as a bonafide tenant.

Delos Reyes claimed that in 1984 through force, intimidation, strategy and stealth, she
and her worker were ejected or prevented by Mendoza and co-defendants from working or
entering their tenanted land, thus violating tenant-landlord agreement.

Section 27. Prohibitions to the Landholder:

(1) The landholder shall not dispossess the tenant of his holdings except for any of the causes enumerated in Section
fifty, and without the cause having been proved before, and the dispossession authorized by, the court; otherwise, he
shall, aside from the penalty of fine and/or imprisonment provided for any violation of this Act, be liable to the
tenant for damages to the extent of the landholder's right under Section twenty-two of this Act.(Agricultural Tenancy
Act of the Philippines)

Initial cases filed against defendants were recovery of possession and damages with a
writ of preliminary mandatory injunction.
Mendoza claimed that Delos Reyes was ejected from subject land due to abandonment,
sublease and mortgage of farm without his consent and approval and nonpayment of rentals.
Mentioned allegations were not proven.
During the pendency of trial, Mendoza was occupying the land and cultivating said
land.
Court decided in favor of the plaintiff, ordering the defendant to restore possession of
the subject land, and enjoining defendants or any person from molesting or interfering with the
possession and cultivation of said land. In addition, Mendoza was ordered to vacate the land
and respect tenancy rights of plaintiff.
Co-defendants were held jointly and severally liable for the lost income/harvest since
1984, 220 cavans of rice or P33, 000 in cash.

Co-defendants appealed claiming that they should not be held liable together with
Mendoza.
Issue: Whether or not Reyes, Parayao & Mananghaya should be jointly and severally
liable together with landlord who dispossessed his tenants unjustly?

Court's ruling:
The court emphasized that it is not a trier of facts but instead put finis to the factual
findings of the case. It agreed with trial court's findings that co-defendants participated in the
dispossession of the plaintiffs thus they should be held liable together with the main
defendant, Mendoza.