GR L 17439; (October, 1962) (Digest)
G.R. No. L-17439; October 31, 1962
JOSE IRA and CONSUELO DE IRA, plaintiffs-appellees, vs. MARINA ZAFRA and ALFREDO LEGASPI, defendants-appellants.
FACTS
The plaintiffs, Jose and Consuelo de Ira, originally filed a forcible entry and detainer case against defendants Marina Zafra and Alfredo Legaspi over an agricultural land. The Justice of the Peace Court of Bocaue, Bulacan, dismissed the case for lack of jurisdiction, opining the dispute involved tenancy relations falling under the exclusive jurisdiction of the Court of Agrarian Relations (CAR). On appeal to the Court of First Instance (CFI) of Bulacan, the parties submitted a “Stipulation of Facts” during trial. This stipulation allowed defendants to work the land for the 1956-1957 agricultural year on a 60-40 sharing arrangement, after which they obligated themselves to vacate and deliver the land to the plaintiffs in exchange for becoming tenants on another lot owned by the plaintiffs in Bigaa, Bulacan. The CFI approved this agreement and rendered a judgment based on it.
ISSUE
Whether the CFI had jurisdiction to approve the stipulation and enforce it via execution and contempt proceedings, given that the stipulation confirmed a tenancy relationship.
RULING
The Supreme Court ruled that the CFI had no jurisdiction. A cursory reading of the stipulation revealed that the defendants had been working the land, and a tenancy relationship was either pre-existing or was expressly created by the parties’ agreement to a 60-40 sharing arrangement for the agricultural year. This placed the controversy squarely within the original and exclusive jurisdiction of the Court of Agrarian Relations under Republic Act No. 1267 , as amended. The subsequent promise to exchange the land under cultivation for another did not alter the fundamental nature of the dispute as one involving tenancy relations. The security of tenure provisions of the Agricultural Tenancy Act ( Republic Act No. 1199 ) govern the ejectment of tenants, which can only be authorized by the CAR for specific statutory causes. The CFI’s approval of the stipulation and its orders for execution and contempt, which effectively sanctioned the defendants’ dispossession, were acts beyond its jurisdiction. Consequently, all proceedings before the CFI were declared null and void, and the appealed orders were set aside. The case was dismissed.