G.R. No. L-26151 October 22, 1970
ALBERTO VALINO, petitioner, vs. HON. EMANUEL M. MUÑOZ, HON. NUMERIANO INUMERABLE and HERMINIO VASALLO, respondents.

FACTS

Petitioner Alberto Valino was the agricultural lessee of lands owned by private respondent Herminio Vasallo. On January 22, 1964, the Court of Agrarian Relations (CAR) rendered a decision in CAR Case No. 909-Bul. ’63, approving an amicable settlement. The settlement authorized Vasallo to eject Valino from the landholding, but suspended execution as long as Valino complied with obligations to pay yearly rentals and a debt in palay. It stipulated that any violation by Valino would entitle Vasallo to immediate execution of the judgment to eject him.
Alleging Valino’s failure to comply, Vasallo dispossessed him of the landholding on April 27, 1965, and replaced him with a new tenant. Valino filed a criminal complaint against Vasallo with the Municipal Court of San Ildefonso, Bulacan (Criminal Case No. 817) for illegal dispossession under the Land Reform Code. He also filed a complaint for damages with the CAR (CAR Case No. 1186), based on the same act of dispossession.
During the criminal proceedings, Vasallo moved to suspend the case, arguing that the issue of whether the dispossession was justified was a prejudicial question falling under the exclusive jurisdiction of the CAR. The municipal judge denied the motion. Vasallo then filed an action for prohibition with the Court of First Instance of Bulacan, which issued an order enjoining the municipal judge from continuing the criminal case until after CAR Case No. 1186 was disposed of. Valino, who was not originally made a party to the prohibition case, intervened and moved for reconsideration, but his motion was denied. He then filed the present petition for certiorari.

ISSUE

Whether the respondent judge of the Court of First Instance acted without or in excess of jurisdiction or with grave abuse of discretion in enjoining the criminal proceedings in the municipal court pending resolution of the related agrarian case.

RULING

The Supreme Court denied the petition, upholding the injunction but on a different ground. The Court clarified that the determination by the CAR of whether ejectment was justified under the Land Reform Code is not a prejudicial question to criminal liability for dispossession without prior judicial authority. However, in this specific case, the CAR had already granted authority to eject Valino through the compromise judgment in CAR Case No. 909-Bul. ’63. The issue was not the absence of CAR authority, but whether Vasallo properly exercised that authority based on Valino’s alleged violation of the settlement terms.
The Court held that until the CAR, which rendered the compromise decision, determines whether the authority to eject was properly exercised, it is logical and proper to hold the criminal case in abeyance. Thus, the respondent superior judge acted properly in enjoining the criminal proceedings. The Court also addressed procedural objections, noting that defects in verification are formal and not jurisdictional, and that Valino was not deprived of his day in court as his motion to intervene was granted and considered.