ACSAY MANDIH, plaintiff-appellant, vs. GREGORIO TABLANTIN, defendant-appellee.
FACTS
Plaintiff-appellant Acsay Mandih filed a complaint for ejectment in the Justice of the Peace Court of Sindangan, Zamboanga del Norte, on December 10, 1954. He alleged ownership and possession for over fifteen years of an agricultural land. He claimed that defendant-appellee Gregorio Tablantin worked as his tenant on a portion of the land in 1952, but after the October 1954 harvest, Tablantin refused to deliver plaintiff’s share of the produce and also refused to vacate the land, instead claiming ownership himself. Tablantin, in his answer, asserted that he had occupied, cultivated, and possessed the land in the concept of an owner since 1947, had introduced improvements, and had filed a Homestead application for it. The Justice of the Peace Court ruled in favor of Mandih, ordering Tablantin to vacate and pay monthly rental. Tablantin appealed to the Court of First Instance (CFI). In the CFI, Tablantin filed an urgent motion to dismiss, arguing that under Republic Act No. 1199 (Agricultural Tenancy Act of 1954) and Republic Act No. 1267, cases involving dispossession of a tenant fall under the original and exclusive jurisdiction of the Court of Industrial Relations (later the Court of Agrarian Relations). Mandih opposed, contending that since Tablantin denied the tenancy relationship and claimed ownership, the action was one for unlawful detainer under the Rules of Court. The CFI granted the motion to dismiss, citing precedent. Mandih appealed this order of dismissal.
ISSUE
Whether the Court of First Instance (or the Justice of the Peace Court on appeal) had jurisdiction over the ejectment case, or whether jurisdiction exclusively pertained to the Court of Agrarian Relations (formerly the Court of Industrial Relations) under the Agricultural Tenancy Act, even when the defendant-tenant denies the tenancy relationship and claims ownership of the land.
RULING
The Supreme Court affirmed the order of dismissal, holding that jurisdiction lies with the Court of Agrarian Relations. The Court rejected appellant’s argument that a tenant’s denial of the landlord-tenant relationship and claim of ownership terminates the relationship and removes the case from agrarian jurisdiction. Section 21 of Republic Act No. 1199 explicitly grants the Court of Industrial Relations (succeeded by the Court of Agrarian Relations) original and exclusive jurisdiction over “all cases involving the dispossession of a tenant by the landlord.” The law does not exempt cases where the tenant claims ownership. The complaint itself alleged a tenancy relationship, and the jurisdictional grant is comprehensive. The Supreme Court cited its prior ruling in Basilio vs. David (98 Phil., 955) to support this interpretation. Therefore, the CFI correctly dismissed the complaint for lack of jurisdiction. Costs were imposed on the plaintiff-appellant.
