GR L 1609; (May, 1949) (Digest)
G.R. No. L-1609. May 30, 1949.
REMIGIO M. PEÑA, petitioner, vs. FRANCISCO ARELLANO, Judge of First Instance of Negros Occidental, and JOSE ECHAUZ, respondents.
FACTS
Respondent Jose Echauz filed an unlawful detainer (detentacion) case in the Justice of the Peace (JP) Court of Hinigaran against his alleged tenants, Marcelo Jampolina and Rustico Mata, seeking their ejectment from his hacienda.
The JP Court, motu proprio, changed the title and docket number of the case from a civil detainer case to a tenancy (aparceria) case.
The JP Court then proceeded to hear it as a tenancy case and submitted its report to the Department of Justice, recommending dismissal of the ejectment for lack of cause under tenancy laws.
Echauz moved for reconsideration, opposing the conversion, but was denied. He then filed a petition for certiorari and mandamus with the Court of First Instance (CFI).
The CFI, through Judge Francisco Arellano, granted the petition, declared the JP’s conversion of the case null and void, and ordered the JP to revert the case to an unlawful detainer case and decide it on its merits.
The JP (petitioner Peña) sought reconsideration and then appealed the CFI’s order, but his appeal was not given due course. He then filed the present petition for certiorari against Judge Arellano.
ISSUE
Whether the Court of First Instance acted without or in excess of its jurisdiction when it ordered the Justice of the Peace Court to treat the case as an unlawful detainer case instead of a tenancy case.
RULING
Yes. The decision of the Court of First Instance is reversed.
Under Republic Act No. 44, which amended Commonwealth Act No. 461, the Department of Justice is the entity authorized to decide tenancy (aparceria) disputes. Neither the Justice of the Peace Court nor the Court of First Instance has original jurisdiction over such matters.
Any party aggrieved by a decision of the Department of Justice may appeal to the Court of Industrial Relations.
Therefore, the CFI Judge acted without jurisdiction when he ordered the JP Court to convert the tenancy case back into an unlawful detainer case and to decide it. The JP Court correctly treated the case as a tenancy matter under the governing law.
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