GR L 3737; (November, 1950) (Digest)
G.R. No. L-3737 December 27, 1950
MELCHOR DAMASCO, FABIAN TOBIAS and IRINEO PANSOY, petitioners, vs. CIRIACO MONTEMAYOR, LUIS ORTEGA as Judge of the Court of First Instance of Pangasinan, and THE PROVINCIAL SHERIFF, respondents.
FACTS
Petitioners were tenants of respondent Ciriaco Montemayor. Montemayor filed an ejectment case against them in the Justice of the Peace Court. Petitioners moved to dismiss, arguing the court lacked jurisdiction as the case involved a tenancy contract. The motion was denied. Petitioners then filed a prohibition case in the Court of First Instance (CFI) to stop the Justice of the Peace Court from trying the ejectment case. In the CFI, the parties entered into a compromise agreement, approved by the court in a judgment. The compromise stipulated that petitioners would deliver palay as rental, the lease would terminate on December 31, 1949, if not renewed, and Montemayor would pay a small sum to each petitioner. After the lease term ended without renewal, Montemayor filed a petition for execution of the judgment to obtain possession of the land. The CFI granted the motion and issued a writ of execution. Petitioners filed this certiorari action to annul the writ.
ISSUE
Whether the Court of First Instance acted without jurisdiction in issuing a writ of execution to enforce the compromise judgment, which ordered the ejectment of the petitioners-tenants.
RULING
Yes. The Supreme Court granted the petition and set aside the writ of execution. First, the CFI acted outside its jurisdiction. The sole issue before it in the prohibition case was the jurisdiction of the Justice of the Peace Court over the ejectment matter. The compromise agreement, which dealt with the termination of the lease and possession, was foreign to that issue. Thus, the court’s approval of the compromise was ultra vires, rendering the agreement a mere extrajudicial contract unenforceable by a writ of execution. Second, the compromise judgment itself contained no order for the delivery of possession, and a writ of execution cannot go beyond the terms of the judgment. Finally, as the petitioners were tenants under a rice tenancy contract, the law vested exclusive original jurisdiction over petitions for their ejectment in the Tenancy Division of the Department of Justice (and the Court of Industrial Relations on appeal), not the regular courts.
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