G.R. No. L-31963 August 31, 1978
ANGEL CUNANAN, petitioner, vs. HON. ANDRES C. AGUILAR, Judge of the CFI of Pampanga, Branch II, Provincial Sheriff of Pampanga, Provincial Commander, PC Command Pampanga, and HEIRS OF CIRIACO RIVERA, respondents.

FACTS

Ciriaco Rivera filed a civil case for recovery of possession against Pragmacio Paule and others over an agricultural land in Lubao, Pampanga. The Court of First Instance (CFI) ruled in Rivera’s favor, a decision which became final and executory. The Rivera heirs were placed in possession in October 1969. Subsequently, petitioner Angel Cunanan initiated a separate case before the Court of Agrarian Relations (CAR), claiming to be the agricultural tenant of the losing defendant, Pragmacio Paule, since 1965. The CAR issued interlocutory orders to maintain Cunanan in possession.
The Rivera heirs then filed a motion in the original CFI case to cite Cunanan for contempt for disobeying the final judgment by refusing to vacate. Cunanan argued the CFI had no jurisdiction because the CAR, having taken cognizance of the tenancy issue, had exclusive jurisdiction. The CFI rejected this, holding Cunanan in contempt and ordering his ouster. Cunanan elevated the matter to the Supreme Court via prohibition.

ISSUE

Whether the Court of First Instance retained jurisdiction to enforce its final judgment for recovery of possession by ousting Angel Cunanan, notwithstanding his claim of tenancy and the pendency of a case before the Court of Agrarian Relations.

RULING

The Supreme Court ruled in favor of the respondents and upheld the CFI’s jurisdiction and order. The legal logic is anchored on the principle of conclusiveness and finality of judgments and the nature of tenancy relations. The CFI’s judgment in the recovery case had long become final and executory, establishing the Rivera heirs as the lawful owners entitled to possession. A tenancy relationship can only be created with the consent of the true and lawful landholder. Pragmacio Paule, from whom Cunanan claims a tenancy, was adjudged a usurper with no rightful interest in the land. Consequently, Paule could not have validly constituted Cunanan as a tenant. Cunanan’s claim did not create a genuine tenancy issue cognizable by the CAR because it was not asserted against the true landowner.
The CAR’s assumption of jurisdiction was therefore erroneous, as it cannot confer rights based on a void relationship with a dispossessed party. The CFI, having rendered a final judgment, retained the inherent power to execute and enforce its decree against all persons unlawfully withholding possession, including Cunanan who derived his claim from the defeated defendant. His refusal to vacate constituted defiance of a lawful order, justifying the contempt citation. The petition for prohibition was dismissed.