G.R. No. L-14579. June 30, 1961.
Pedro Gabani, et al., petitioners-appellees, vs. Juan E. Reas, et al., respondents-appellants.

FACTS

Juan E. Reas filed an unlawful detainer case against Pedro Gabani and others in the Justice of the Peace Court of Wright, Samar. The defendants moved to dismiss for lack of jurisdiction, but the motion was denied. After trial, the inferior court ordered the defendants to pay rentals in palay and corn, vacate the land, and pay damages and attorney’s fees. Execution of the judgment was later issued. The defendants, unable to post a bond to stay execution, filed a special civil action for certiorari in the Court of First Instance (CFI) of Samar. They alleged the inferior court exceeded its jurisdiction by awarding damages and attorney’s fees and by ordering execution. They sought annulment of the decision and an award of moral damages.
The respondents moved to dismiss the certiorari petition, arguing it stated no cause of action, the Justice of the Peace Court had jurisdiction, and the petitioners had a right to appeal. The CFI denied the motion to dismiss and, after hearing, rendered judgment declaring the inferior court’s decision null and void and ordering respondent Reas to pay damages and attorney’s fees to the petitioners. The respondents appealed this CFI decision to the Supreme Court.

ISSUE

Whether the Court of First Instance correctly annulled the decision of the Justice of the Peace Court for lack of jurisdiction over the unlawful detainer case.

RULING

Yes, the CFI correctly annulled the decision. The Supreme Court examined the allegations in the complaint filed in the Justice of the Peace Court. It stated the defendants contracted to plant rice and corn on the plaintiff’s land, agreeing to pay a yearly rental of a fixed quantity of palay and corn. This arrangement constitutes a leasehold tenancy as defined under the Agricultural Tenancy Act ( Republic Act No. 1199 , as amended). The case involved the dispossession or ejectment of a tenant by a landholder from agricultural land cultivated in consideration of a certain price.
The law governing jurisdiction over such disputes is explicit. Section 21 of the Agricultural Tenancy Act provides that all cases involving the dispossession of a tenant by the landholder shall be under the original and exclusive jurisdiction of the court authorized by law to take cognizance of tenancy relations. Section 7 of the amendatory Act ( Republic Act No. 1267 ) designates the Court of Agrarian Relations as the court with original and exclusive jurisdiction over all questions and disputes involving relationships in the cultivation of agricultural land where one party works the land. Therefore, the subject matter of the ejectment case fell squarely within the exclusive original jurisdiction of the Court of Agrarian Relations, not the Justice of the Peace Court. Since the inferior court acted without jurisdiction, its decision was null and void. The Supreme Court affirmed the CFI’s judgment annulling that decision.