GR 118691; (July, 1996) (Digest)
G.R. No. 118691 July 5, 1996
ALEJANDRO BAYOG and JORGE PESAYCO, JR., petitioners, vs. HON. ANTONIO M. NATINO, Presiding Judge, Regional Trial Court, Branch 12, San Jose, Antique, and ALBERTO MAGDATO, respondents.
FACTS
Petitioner Alejandro Bayog and respondent Alberto Magdato entered into an Agricultural Leasehold Contract. Magdato was later issued a Certificate of Agricultural Leasehold under P.D. No. 27. Subsequently, Bayog executed a Deed of Equitable Mortgage over the land. Bayog and Jorge Pesayco, Jr. filed an ejectment complaint against Magdato before the Municipal Circuit Trial Court (MCTC). Magdato filed his Answer three days late. The MCTC, applying the Rule on Summary Procedure, declared the Answer filed out of time and rendered a judgment by default, ordering Magdato’s ejectment and the demolition of his house. The judgment was executed.
Magdato filed a petition for relief from judgment with the Regional Trial Court (RTC), alleging his late filing was due to excusable neglect from illness and illiteracy. The RTC granted the petition, set aside the MCTC judgment, and remanded the case. Bayog and Pesayco filed this certiorari petition, arguing the RTC acted without jurisdiction as the MCTC judgment was already final and executed.
ISSUE
Whether the Regional Trial Court acted with grave abuse of discretion in granting the petition for relief from judgment and setting aside the final and executed judgment of the Municipal Circuit Trial Court.
RULING
No, the RTC did not commit grave abuse of discretion. The Supreme Court upheld the RTC’s order. The core legal logic rests on the nature of agrarian disputes and the propriety of relief from judgment. First, the MCTC’s outright dismissal of the late Answer was a procedural error. Under the Rule on Summary Procedure, while a late answer may not be admitted, the court must still proceed to render judgment based on the evidence submitted by the plaintiff. The MCTC erred by treating the late filing as a total waiver of Magdato’s right to present evidence, effectively declaring him in default—a procedure prohibited in summary proceedings.
Second, and decisively, the substantive issue involved an agrarian dispute over an agricultural leasehold relationship, evidenced by a Certificate issued under P.D. No. 27. Jurisdiction over such disputes is vested in the Department of Agrarian Reform Adjudication Board (DARAB) and its adjudicators, not regular courts. Therefore, the MCTC never acquired jurisdiction over the ejectment case in the first place. A judgment rendered by a court without jurisdiction is void ab initio and can be assailed at any time. Consequently, the RTC correctly set aside the void MCTC judgment. The fact of execution did not cure its jurisdictional infirmity. The petition for certiorari was dismissed.