GR L 12560; (September, 1958) (Digest)
G.R. No. L-12560; September 30, 1958
JOSE ROBLES, petitioner-appellant, vs. ZAMBALES CHROMITE MINING COMPANY, ET AL., respondents-appellees.
FACTS
On November 28, 1956, Zambales Chromite Mining Company filed a complaint for unlawful detainer against Jose Robles in the Justice of the Peace Court of Sta. Cruz, Zambales. The complaint alleged that the Company and Robles had entered into a contract whereby the Company delivered possession of certain mining properties under its control to Robles. Under the contract, Robles was to extract, mine, and sell ores from these properties in exchange for payment of royalties. The Company claimed that Robles violated the contract’s terms, and after serving a notice to vacate, Robles failed to comply. Robles filed a motion to dismiss the complaint, arguing that the Justice of the Peace Court lacked jurisdiction over an unlawful detainer case involving mineral land. The motion was denied. Robles then filed a petition for certiorari in the Court of First Instance of Zambales, reiterating his jurisdictional challenge. The Court of First Instance ruled against Robles, holding that the provisions of Section 1, Rule 72 of the Rules of Court were broad enough to cover any kind of land, including mineral land. Robles appealed this decision.
ISSUE
Whether the Justice of the Peace Court (the proper inferior court) has jurisdiction over an action for unlawful detainer involving mineral land.
RULING
Yes. The Supreme Court affirmed the decision of the Court of First Instance, holding that the Justice of the Peace Court had jurisdiction. The Court based its ruling on Section 1, Rule 72 of the Rules of Court, which allows a person unlawfully deprived of possession of “any land or building” to bring an action for restitution within one year. The Court applied the statutory construction maxim that “where the law does not distinguish, we should not distinguish.” Since the rule uses the broad term “any land” without qualification or exception, it necessarily includes all classifications of land, whether agricultural, residential, or mineral. Therefore, an unlawful detainer action is available for the recovery of possession of mineral lands. The appeal was dismissed, and costs were imposed on appellant Jose Robles.