G.R. No. L-20724 November 18, 1967
Segundino Dimitui, et al., petitioners, vs. Court of Agrarian Relations of Pampanga, et al., respondents.

FACTS

Petitioners Francisco Bondoc, Andres Mandap, and Placido Simon are tenants on sugar cane and rice landholdings (Lots Nos. 269-D and 269-C) in San Simon, Pampanga. On December 1, 1960, respondents Ernesto Dimitui and Mamerta Bondoc Vda. de Dimitui filed a petition (Tenancy Case No. 894) with the respondent Court of Agrarian Relations to order these tenants to recognize them as lawful landlords instead of petitioner Segundino Dimitui and to stop Segundino from interfering. The tenants moved to dismiss, citing a pending ownership dispute in Civil Case No. 1832 before the Court of First Instance of Pampanga, but the agrarian court denied the motion on January 10, 1961, presuming the validity of respondents’ purchase. On November 27, 1961, Ernesto Dimitui filed another petition (Tenancy Case No. 1095) to eject tenants of Lot 269-D for alleged violations and to implead Segundino Dimitui to prevent him from acting as landholder. On June 18, 1962, the respondents in the tenancy cases moved to suspend proceedings pending the civil case’s outcome, and on June 26, 1962, moved to dismiss. The court denied both motions on July 18, 1962. On August 16, 1962, the agrarian court issued an interlocutory order in Case No. 894 directing the three tenants to recognize Ernesto Dimitui and Mamerta Bondoc as their landholders during the pendency of the case. Petitioners seek to prohibit the agrarian court from proceeding and to nullify this order for lack of jurisdiction.

ISSUE

Whether the Court of Agrarian Relations has jurisdiction over the tenancy cases despite a pending civil action in the Court of First Instance disputing ownership of the landholding.

RULING

The Court of Agrarian Relations has jurisdiction. The sale of Lot 269-D to Ernesto Dimitui at a sheriff’s auction on May 29, 1959, is presumed valid until annulled by a regular court. Under Section 9 of the Agricultural Tenancy Act ( Republic Act No. 1199 , as amended), the sale of land does not extinguish the tenancy relationship, and the purchaser assumes the rights and obligations of the former landholder. Thus, a tenancy relationship between the tenants and Ernesto Dimitui is created by law, irrespective of any prior contract. The mere pendency of a suit to invalidate the sale does not deprive it of legal effect pending final judgment. Furthermore, the agrarian court has inherent power to compel obedience to its orders and control persons connected with a case to ensure its decrees are not nugatory; therefore, it acted within its jurisdiction in ordering Segundino Dimitui not to interfere. The writs of certiorari and prohibition are denied.