G.R. No. L-62082 February 26, 1992
PHILIPPINE NATIONAL BANK, petitioner, vs. THE HON. TEODORO N. FLORENDO, Judge of the Court of Agrarian Relations, 12th Regional District, Branch IV, Dumaguete City, VIVIENNE B. VILORIA, SOCORRO MISA, GERMELIN ESTORCO, PABLO BENDOLO, REWEL CABUAL, BONIFACIO VALEROSO, ET. AL., respondents.

FACTS

Private respondents, as tenants, filed a complaint in the Court of Agrarian Relations (CAR) to nullify the foreclosure by PNB of four parcels of agricultural land in Mabinay, Negros Oriental, alleging a violation of P.D. Nos. 27 and 946. The lands were mortgaged by the owners, the Viloria spouses, to PNB, which later foreclosed and acquired them at auction. The tenants claimed the foreclosure was improper as the lands were under the government’s Land Reform Program.
Subsequently, the private respondents moved to amend their complaint to include an additional parcel of land covered by TCT No. 42836, a residential lot located in Cebu City. They argued this Cebu lot was indivisible from the mortgaged Negros Oriental lands under a single real estate mortgage contract. PNB opposed the amendment, contending the CAR had no jurisdiction over a residential lot not subject to agrarian reform. The respondent judge admitted the First Amended Complaint, prompting PNB to file this certiorari petition.

ISSUE

Whether the respondent judge acted in excess of jurisdiction by admitting the First Amended Complaint which included a residential lot not covered by Operation Land Transfer under P.D. 27.

RULING

Yes, the respondent judge exceeded his jurisdiction. The Court of Agrarian Relations was a court of limited jurisdiction, confined to agrarian disputes. Its jurisdiction was defined by statute and limited to matters falling under agrarian laws like P.D. 27, which applied only to agricultural lands. The parcel of land in Cebu City, being residential, was clearly outside the scope of Operation Land Transfer and thus beyond the CAR’s jurisdictional authority.
The legal logic is that a court cannot acquire jurisdiction over a subject matter not conferred by law. By admitting an amendment that incorporated a cause of action over which it inherently lacked jurisdiction, the CAR judge acted in excess of jurisdiction. An act is in excess of jurisdiction when a court, although possessing jurisdiction over the main case, oversteps its authority by exercising power over a matter not within its legal competence. Since the CAR had no power to adjudicate issues involving a residential lot, its order admitting the amended complaint was void for lack of jurisdiction over that new subject matter. Certiorari is the proper remedy to correct such a jurisdictional defect, even if an appeal was available, as the order was a nullity. The Supreme Court granted the petition, annulled the contested orders, and made permanent the restraining order regarding the Cebu lot.