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OTILIA STA. ANA v. SPS. LEON G. CARPO AND AURORA CARPO

This case has been cited 7 times or more.

	GR No. 179643 2013-06-03	ERNESTO L. NATIVIDAD v. FERNANDO MARIANO BRION, J.
The agricultural lessee's failure to pay the lease rentals, in order to warrant his dispossession of the landholding, must be willful and deliberate and must have lasted for at least two (2) years. The term "deliberate" is characterized by or results from slow, careful, thorough calculation and consideration of effects and consequences, while the term "willful" is defined, as one governed by will without yielding to reason or without regard to reason.[58] Mere failure of an agricultural lessee to pay the agricultural lessor's share does not necessarily give the latter the right to eject the former absent a deliberate intent on the part of the agricultural lessee to pay.[59]
	GR No. 169913 2011-06-08	HEIRS OF DR. JOSE DELESTE v. LAND BANK OF PHILIPPINES VELASCO JR., J.
Time and again, this Court has held that a strict and rigid application of technicalities must be avoided if it tends to frustrate rather than promote substantial justice.[39] As held in Sta. Ana v. Spouses Carpo:[40]
	GR No. 179844 2011-03-23	EMERSON B. BAGONGAHASA v. JOHANNA L. ROMUALDEZ NACHURA, J.
However, this Court refuses to rule on the validity of the CARP coverage of the subject properties and the issuance of the assailed CLOAs. The doctrine of primary jurisdiction precludes the courts from resolving a controversy over which jurisdiction was initially lodged with an administrative body of special competence.[21] The doctrine of primary jurisdiction does not allow a court to arrogate unto itself authority to resolve a controversy, the jurisdiction over which is initially lodged with an administrative body of special competence.[22] The Office of the DAR Secretary is in a better position to resolve the particular issue of non-issuance of a notice of coverage - an ALI case - being primarily the agency possessing the necessary expertise on the matter.[23] The power to determine such issue lies with the DAR, not with this Court.
	GR No. 182332 2011-02-23	MILESTONE FARMS v. OFFICE OF PRESIDENT NACHURA, J.
Finally, it is established that issues of Exclusion and/or Exemption are characterized as Agrarian Law Implementation (ALI) cases which are well within the DAR Secretary's competence and jurisdiction.[65] Section 3, Rule II of the 2003 Department of Agrarian Reform Adjudication Board Rules of Procedure provides: Section 3. Agrarian Law Implementation Cases.
	GR No. 168959 2010-03-25	NAPOLEON MAGNO v. GONZALO FRANCISCO CARPIO, ACTING CJ.
It is undisputed that petitioner and respondents have an established tenancy relationship, such that the complaint for collection of back rentals and ejectment is classified as an agrarian dispute and under the jurisdiction of the PARAD and thereafter by the DARAB. However, in view of the conflicting claims where petitioner asserted ownership over the lot and respondents emphasized that the lot is subject to OLT coverage, there is a need to ascertain if the lot is under the agrarian reform program. Since the classification and identification of landholdings for coverage under the agrarian reform program are Agrarian Law Implementation cases, the DAR Secretary should first resolve this issue. In Sta. Ana v. Carpo,[52] we held: Verily, there is an established tenancy relationship between petitioner and respondents in this case. An action for Ejectment for Non-Payment of lease rentals is clearly an agrarian dispute, cognizable at the initial stage by the PARAD and thereafter by the DARAB. But issues with respect to the retention rights of the respondents as landowners and the exclusion/exemption of the subject land from the coverage of agrarian reform are issues not cognizable by the PARAD and the DARAB, but by the DAR Secretary because, as aforementioned, the same are Agrarian Law Implementation (ALI) Cases. (Boldfacing supplied)
	GR No. 169958 2010-03-05	DEPARTMENT OF JUSTICE SECRETARY RAUL M. GONZALEZ v. MICHAEL ALFIO PENNISI CARPIO, J.
Rules of procedure are merely tools designed to facilitate the attainment of justice. If the application of the Rules would tend to frustrate rather than to promote justice, it is always within our power to suspend the rules or except a particular case from their operation. Law and jurisprudence grant to courts the prerogative to relax compliance with the procedural rules, even the most mandatory in character, mindful of the duty to reconcile the need to put an end to litigation speedily and the parties' right to an opportunity to be heard.[11]
	GR No. 162374 2009-06-18	RODOLFO B. ARCEÑO v. GOVERNMENT SERVICE INSURANCE SYSTEM PERALTA, J.
Verily, therefore, the CA was correct in not addressing the issue of whether petitioner should be compensated for his alleged cardiovascular disease, as it is hornbook principle that new issues cannot be raised for the first time on appeal. The Court emphasized this rule in Tan v. Commission on Elections,[10] explaining that the rule is based on principles of fairness and due process, and is applicable to appealed decisions originating from regular courts, administrative agencies or quasi-judicial bodies, whether rendered in a civil case, a special proceeding, or a criminal case.[11] Thus, in Otilia Sta. Ana v. Spouses Leon and Aurora Carpo,[12] it was stated that courts must refrain from entertaining an issue raised by a petitioner for the first time on appeal.