G.R. No. A.M. No. 68-MJ February 25, 1975
Zacarias Junio, complainant, vs. Salvador T. Mananzan, Municipal Judge, Bayambang, Pangasinan, respondent.

FACTS

Complainant Zacarias Junio filed an administrative complaint against Municipal Judge Salvador T. Mananzan for alleged misconduct and partiality. The charge stemmed from the judge’s order dismissing Civil Case No. 173, a forcible entry case filed by Junio against Maximiano and Roman Edoria. The complainant alleged that the defendants had encroached upon his land adjoining a creek. During the pre-trial conference, the parties, assisted by their counsel, voluntarily entered into a “Stipulation of Facts.” They agreed that the case was essentially a boundary dispute and stipulated that a licensed surveyor would conduct a relocation survey. The findings of this surveyor were to serve as the basis for the court’s final decision in the case.
Based on this stipulation, which framed the core issue as a determination of property boundaries, respondent Judge Mananzan issued an order on January 23, 1969, dismissing the case. The dismissal order stated that the case “partakes of relocation of the boundaries and not forcible entry as alleged therein.” This prompted Junio to file the present administrative complaint, alleging that the judge acted with partiality and misconduct in dismissing the case without awaiting the surveyor’s report as agreed upon in the stipulation.

ISSUE

Whether respondent Judge Salvador T. Mananzan committed misconduct or acted with partiality in dismissing Civil Case No. 173 for lack of jurisdiction.

RULING

The Supreme Court dismissed the administrative complaint and exonerated Judge Mananzan. The Court concurred with the findings and recommendation of the investigating judge, which were sustained by the Department of Justice. The legal logic is clear: jurisdiction over a subject matter is conferred solely by law and cannot be vested by the agreement or stipulation of the parties. The investigating judge found, and the Supreme Court affirmed, that the case involved a boundary dispute over the northern limits of adjoining properties, not a legitimate action for forcible entry.
Forcible entry cases fall under the exclusive original jurisdiction of municipal courts, but they require allegations of deprivation of possession by force, intimidation, threat, strategy, or stealth. The stipulation of facts signed by the parties themselves, including complainant’s counsel, explicitly characterized the suit as a “boundary dispute.” This factual admission transformed the nature of the action from one of forcible entry to an action for the determination of ownership or boundary, which is beyond the jurisdiction of a municipal court. Consequently, Judge Mananzan was legally compelled to dismiss the case for lack of jurisdiction. His duty to dismiss a case over which his court has no authority is mandatory and constitutes a proper exercise of judicial function, not an act of misconduct or partiality. The agreement to base a judgment on a surveyor’s report could not confer jurisdiction where none existed by law.