GR L 15264; (December,1961) (Digest)
G.R. No. L-15264 December 22, 1961
GARCIA SAMSON, plaintiff-appellant, vs. RAMON ENRIQUEZ and FERMIN FILOTEO, defendants-appellees.
FACTS
Plaintiff Garcia Samson filed a complaint for recovery of possession and damages in the Municipal Court of Zamboanga City against defendants Ramon Enriquez and Fermin Filoteo. Samson alleged that in 1913, he entered into a “contrato de aparceria” (contract of tenancy) with Jose Borja, acting for himself and as attorney-in-fact for the co-owners of Lot No. 422. Under this contract, Samson took possession of the land to cultivate palay, paying an annual rental of 25 cavans. He claimed peaceful possession until April 13, 1955, when the defendants, by force and intimidation, deprived him of possession and destroyed his bamboo groves.
The defendants moved to dismiss the complaint, contending the Municipal Court lacked jurisdiction. They argued that the action, being founded on a tenancy contract involving a system of cultivation, fell under the exclusive jurisdiction of the Court of Agrarian Relations pursuant to Republic Act No. 1267 , as amended. The Municipal Court agreed, declared itself without jurisdiction, and transmitted the case to the agrarian court. Upon suggestion, it later dismissed the complaint. Samson appealed to the Court of First Instance (CFI).
ISSUE
Whether the Court of First Instance (on appeal) had jurisdiction over the action for recovery of possession, or whether jurisdiction properly pertained to the Court of Agrarian Relations.
RULING
The Supreme Court affirmed the CFI’s order dismissing the appeal for lack of jurisdiction, holding that the case fell within the exclusive jurisdiction of the Court of Agrarian Relations. The legal logic is anchored on the nature of the plaintiff’s own allegations. The complaint unequivocally anchored Samson’s right to possess the land on a “contrato de aparceria,” a specific contract of agricultural tenancy. By pleading this specific contractual relationship, Samson essentially characterized the controversy as one arising from a tenancy agreement involving a system of cultivation on an agricultural land.
Under the then-governing law, Republic Act No. 1267 (creating the Court of Agrarian Relations), as amended, such disputes were placed within the exclusive original jurisdiction of the specialized agrarian court. The jurisdiction is determined by the allegations of the complaint. Since the complaint itself expressly invoked rights under a tenancy contract, the ordinary courts, including the Municipal Court and the CFI (whether acting in its original or appellate capacity), were divested of jurisdiction. The subject matter of the suit—possession based on a tenancy relation—was beyond their competence. Therefore, the CFI correctly dismissed the appeal, leaving the plaintiff to seek redress in the proper forum, the Court of Agrarian Relations.