G.R. No. L-15065; April 28, 1961
CESAR D. MILITAR, petitioner, vs. VENTURA TORCILLERO and HON. RAMON BLANCO, in his capacity as Presiding Judge of the Court of Agrarian Relations, Eighth Regional District, Iloilo City, respondents.

FACTS

In a prior agrarian case (CIR Tenancy Case No. 182-Iloilo), the Court of Agrarian Relations (CAR) adjudged that respondent Ventura Torcillero, a tenant, was unlawfully ejected by petitioner Cesar D. Militar. The court ordered Torcillero’s reinstatement and, in its dispositive portion, expressly reserved his right to file a separate action for damages under Section 19 of Act No. 4054 . Militar did not appeal this judgment, and it became final. Subsequently, Torcillero filed a new petition (CAR Case No. 490-Iloilo) to recover damages representing crop losses and attorney’s fees incurred due to his illegal dispossession. Militar moved to dismiss this subsequent action, arguing that the CAR lacked jurisdiction over a claim for damages and that Torcillero had improperly split his cause of action by not litigating the claim for damages in the original ejectment case.

ISSUE

Whether the Court of Agrarian Relations has jurisdiction to hear the separate action for damages filed by the tenant, and whether such action is barred for splitting a cause of action.

RULING

The Supreme Court ruled that the CAR has jurisdiction and that the separate action is not barred. The Court explained that under Section 7 of Republic Act No. 1267 , as amended, the CAR possesses exclusive original jurisdiction over all controversies arising from landlord-tenant relationships. This jurisdiction logically extends to claims for damages arising from unlawful ejectment, as such claims are intrinsically linked to the tenancy relationship. The Court affirmed the rule against splitting a cause of action, stating that claims for reinstatement and damages from illegal dispossession should ideally be litigated in a single proceeding to prevent multiplicity of suits. However, in this specific instance, the final and executory judgment in the first case contained an explicit reservation granting Torcillero the right to file a separate action for damages. By failing to appeal that judgment to challenge the reservation, Militar effectively waived any objection to the splitting of the cause of action. Consequently, the erroneous reservation, which permitted the separate filing, became binding. Therefore, the subsequent action for damages was properly within the CAR’s jurisdiction and was not barred by the prior judgment. The petition for certiorari was denied.