G.R. No. L-11537; October 31, 1958
Brigida Maristela, for herself and as guardian of her minor children Eduardo, Rosita, Marta, Victor, Reynaldo, Jesus, Ramona and Rafael, all surnamed Rivera, Lamberto Rivera, Belen Rivera and Rodolfo Rivera, petitioners, vs. Hon. Pastor P. Reyes, Associate Judge of the Court of Agrarian Relations, Third District, San Fernando, Pampanga, and Juan M. Valerio, respondents.

FACTS

On December 8, 1954, respondent Juan M. Valerio filed a complaint in the Court of Industrial Relations (later transferred to the Court of Agrarian Relations) to dispossess Cecilio Rivera from an agricultural landholding in Bamban, Tarlac. Cecilio Rivera moved to dismiss the complaint on the ground that the court lacked jurisdiction because a related case was already pending. Specifically, on October 16, 1954 (prior to Valerio’s ejectment complaint), the heirs of the late Alberto Maristela, including Brigida Maristela (Cecilio Rivera’s wife), had filed an action in the Court of First Instance of Tarlac (Civil Case No. 980) seeking the annulment on the ground of fraud of a deed of sale covering a parcel of land, part of which was the subject of Valerio’s ejectment suit. The deed was allegedly executed by Alberto Maristela. The Court of Agrarian Relations denied the motion to dismiss. Cecilio Rivera died on March 21, 1955. His widow, Brigida Maristela, and their children (the petitioners) filed a motion for substitution as respondents in the ejectment case and for reconsideration of the order denying the motion to dismiss. The Court of Agrarian Relations denied these motions and, on September 14, 1956, ordered the petitioners to deliver possession of the land to Valerio after harvest. The court based this order on Section 9 of Republic Act No. 1199 , which extinguishes tenancy upon the tenant’s death, allowing heirs to work only until the close of the agricultural year, and on the assumption that a tenancy relationship existed between Valerio and the deceased Cecilio Rivera. The petitioners then filed the present petition to set aside the agrarian court’s order.

ISSUE

Whether the Court of Agrarian Relations erred in proceeding with and deciding the ejectment case despite the pendency of a prior action in the Court of First Instance involving the validity of the title to the land from which ejectment was sought.

RULING

Yes. The Supreme Court granted the petition. The Court of Agrarian Relations committed an error by assuming the existence of a tenancy relationship between Valerio and Cecilio Rivera without considering the prior pending action (Civil Case No. 980) in the Court of First Instance of Tarlac, which sought to annul the deed of sale covering the very land in question. The validity of Valerio’s title, upon which his right to eject depended, was directly put in issue by that prior case. Therefore, the agrarian court should have held the ejectment case in abeyance until the question of title was finally resolved by the Court of First Instance. The Supreme Court set aside the order of September 14, 1956, directed the Court of Agrarian Relations to allow the substitution of the widow and minor children of Cecilio Rivera as respondents, and enjoined it from proceeding with the ejectment case until after final judgment in Civil Case No. 980. No costs were awarded.