G.R. No. L-10929; March 27, 1958
RAMONA ESCOTO DE MIRANDA, ET AL., petitioners, vs. HON. PASTOR P. RAMOS, ET AL., respondents.

FACTS

Jose Quizon filed a complaint with the Court of Industrial Relations (later transferred to the Court of Agrarian Relations) against Ramona Escoto de Miranda, et al., praying that they respect his possession as tenant of an 8-hectare land in Bacolor, Pampanga. The land was originally owned by Gaudencio Mañalac and worked by Quizon since 1943-1944. In 1945, Santiago Ocampo leased it from Mañalac, retaining Quizon as tenant. On January 16, 1946, Mañalac sold the land to Marcos Miranda, predecessor-in-interest of the respondents (landlords). Upon the lease’s expiration in 1955, the landlords took possession and notified the fourteen tenants, including Quizon, of their intention to convert the land into a fishpond, demanding surrender of holdings. Thirteen tenants verbally agreed to surrender if the landlords proved a bona fide intention to convert, which the landlords did by presenting evidence and commencing dike preparation and flooding. Quizon, however, re-entered and plowed his landholding months later. The landlords then filed an ejectment suit against him before the Justice of the Peace Court of Bacolor, which decided on August 26, 1955, to eject Quizon. He appealed to the court of first instance. Meanwhile, the landlords sought the aid of the Tenancy Division of the Court of Industrial Relations. After a conference where the landlords presented evidence of the land’s original fishpond use, the thirteen tenants agreed to the conversion, but Quizon remained opposed. The commissioner advised Quizon to take the matter to the Court of Industrial Relations, leading to the instant case. The agrarian court found Quizon did not voluntarily surrender possession but was dispossessed via the ejectment case, and ordered his reinstatement and payment of 100 cavanes of palay as his share for 1955-1956. Respondents petitioned for review.

ISSUE

1. Whether the Court of Agrarian Relations had jurisdiction over the controversy.
2. Whether the dispossession of tenant Quizon was justified.
3. Whether the award of 100 cavanes of palay as damages was proper.

RULING

1. Yes, the Court of Agrarian Relations had exclusive jurisdiction. Under Section 21 of Republic Act No. 1199 , all cases involving dispossession of a tenant or disputes arising from the landlord-tenant relationship are under the original and exclusive jurisdiction of the court authorized to take cognizance of tenancy relations. The agrarian court found Quizon did not voluntarily surrender his landholding but was dispossessed through the ejectment suit. Citing Basilio vs. David, the Supreme Court held that when evidence shows a landlord-tenant relationship, the justice of the peace court should dismiss the ejectment case for lack of jurisdiction. Thus, the agrarian court correctly assumed jurisdiction.
2. No, the dispossession was not justified. Under Section 50 of Republic Act No. 1199 , a tenant can only be dispossessed for specific causes, none of which were proven here. The landlords argued that converting the land to a fishpond was a change of crop under Section 25(1) of the same Act, which allows a landholder to choose the crop. However, if the tenant objects, the conflict must be settled by the agrarian court. The landlords failed to do this and instead filed an ejectment case, which cannot prejudice the tenant’s rights. Therefore, Quizon’s separation was unjustified.
3. Yes, the award of damages was proper. The agrarian court’s finding that Quizon was entitled to 100 cavanes of palay representing his share for 1955-1956 was based on evidence of his previous harvests: a net share of 108 cavanes in 1954-1955, a gross harvest of 202 cavanes in 1953-1954, and 260 cavanes in 1952-1953. This factual finding is binding on the Supreme Court under Section 16 of Republic Act No. 1267 , as amended.
MODIFICATION: Considering the landlords had begun converting the land, and to avoid hardship if the work on Quizon’s portion was advanced, the landlords were given an alternative: either retain Quizon as a worker in the fishpond if qualified, or provide him another portion of land of equal area under similar tenancy terms. The decision was affirmed with this modification. No costs.