G.R. No. 55457 January 20, 1989
FILOMENO QUILLIAN, petitioner, vs. HON. COURT OF APPEALS, SILVERIO ALIT, PRIMO ESLEYER and CONSTANCIO GEOLINGO, respondents.

FACTS

The case originated from a complaint for reinstatement filed by petitioner Filomeno Quillian against landowner Silverio Alit and lessees Constancio Geolingo and Primo Esleyer. Quillian claimed he was a tenant on a portion of Alit’s land and was forcibly ejected. The land was initially leased by Alit to Geolingo under a contract expressly prohibiting the placement of tenants. Quillian and another individual signed a document stating they would work as paid laborers, not tenants, for Geolingo during the lease term. After the lease, Alit leased the land to Esleyer under a similar contract prohibiting tenancy.
The trial court ruled in favor of Quillian, ordering his reinstatement. On appeal, the Court of Appeals reversed, setting aside the trial court’s decision and ordering the remand of the case to the trial court for referral to the Minister of Agrarian Reform pursuant to Section 2 of Presidential Decree No. 316. The appellate court held that such referral for a preliminary determination of the tenancy relationship was a mandatory jurisdictional requirement. Quillian elevated the case to the Supreme Court via certiorari.

ISSUE

The primary issue is whether the Court of Appeals erred in ruling that the case must be referred to the Ministry of Agrarian Reform under P.D. No. 316, and consequently, whether the trial court’s decision should be reinstated or the case decided on its merits.

RULING

The Supreme Court reversed the Court of Appeals and dismissed Quillian’s complaint. The Court held that Section 2 of P.D. No. 316 applies only to “any ejectment case or any other case designed to harass or remove a tenant.” The provision mandates referral to the Secretary of Agrarian Reform for a preliminary determination of the landlord-tenant relationship before a court can take cognizance of such cases. However, the instant case was filed by Quillian himself for reinstatement; it was not an action initiated by a landowner to eject or harass a tenant. Therefore, the mandatory referral requirement under P.D. No. 316 was not applicable.
Since the purpose of the referral is to prevent harassment of tenants, it is logically inapplicable to a suit filed by the alleged tenant. The Court further ruled that, even assuming referral was required, the certification from the district officer of the Ministry of Agrarian Reform in Bacolod City was sufficient, as he was a duly authorized representative. More importantly, the Court found it proper to decide the case on the merits based on the established facts. The document signed by Quillian unequivocally declared him to be a paid laborer, not a tenant. This stipulation was valid and binding, as it was made pursuant to the lease agreement between Alit and Geolingo which prohibited tenancy. Parties are bound by their contractual commitments that are not contrary to law, morals, or public policy. Consequently, Quillian had no tenancy rights to enforce.