GR L 14241; (February, 1962) (Digest)
G.R. No. L-14241. February 26, 1962.
INOCENCIO MIJARES, ET AL., plaintiffs-appellants, vs. JULIAN ADIGUE, ET AL., defendants-appellees.
FACTS
The spouses Inocencio Mijares and Coronacion Ipos filed an action for forcible entry concerning a parcel of land in Palanas, Masbate, against Julian Adigue and his son, Pedro, in the local Justice of the Peace Court. After trial, the court ruled in favor of the plaintiffs. The defendants appealed this decision to the Court of First Instance (CFI) of Masbate, where it was docketed as Civil Case No. 816.
Subsequently, Judge Ambrosio T. Dollete of the CFI of Bataan, temporarily assigned to the CFI of Masbate, issued Administrative Order No. 4 on October 5, 1957. This order referred several cases, including Civil Case No. 816, to the Justice of the Peace of Masbate for trial and judgment. Prior to the trial before the Justice of the Peace, the plaintiffs filed a motion for the return of the case to the CFI, arguing that the delegation of jurisdiction was invalid under Section 88 of Republic Act No. 296 (The Judiciary Act of 1948). The Justice of the Peace Court denied the motion and, upon the plaintiffs’ insistence, issued an order on January 13, 1958, dismissing the case. The plaintiffs appealed this dismissal.
ISSUE
Whether the Court of First Instance of Masbate had the authority to delegate the trial and disposition of the appealed forcible entry case to the Justice of the Peace Court.
RULING
The Supreme Court reversed the order of dismissal and held that the CFI of Masbate had no authority to delegate the case. The legal logic centers on the proper interpretation of Section 88 of the Judiciary Act of 1948, as amended. This provision enumerates the limits of the jurisdiction of justices of the peace and municipal judges. It explicitly states that their jurisdiction “shall not extend to civil actions in which the subject of litigation is not capable of pecuniary estimation, except in forcible entry and detainer cases.” The Court interpreted this clause as a specific grant of original jurisdiction to inferior courts over forcible entry cases. It does not, however, authorize a CFI to delegate or refer an appealed forcible entry case, which is already within its appellate jurisdiction, back to an inferior court for trial and judgment. Such a delegation finds no support in the statutory language.
Furthermore, the appellants correctly claimed that the administrative order effecting the delegation lacked the approval of the Secretary of Justice. The proviso in Section 88 allowing delegation in specific instances (e.g., for qualified justices of the peace to handle certain cadastral cases) explicitly requires such approval. This procedural defect reinforced the invalidity of the order. Consequently, the case was improperly referred. The Supreme Court ordered the record of Civil Case No. 816 to be returned from the Justice of the Peace Court of Masbate to the CFI of Masbate for proper trial on the merits and judgment.