GR L 20547; (April, 1965) (Digest)
G.R. No. L-20547 April 30, 1965
CIPRIANO TUVERA and ROMAN MARQUEZ, petitioners, vs. HON. PASTOR DE GUZMAN, HON. TOMAS P. PANGANIBAN and ASUNCION V. SANCHEZ, respondents.
FACTS
Asuncion V. Sanchez filed a complaint for “liquidation [of harvest], injunction and ejectment” against Cipriano Tuvera and Roman Marquez in the Court of Agrarian Relations. She alleged that Tuvera and Marquez were her share-tenants on her 3.5-hectare agricultural land in Villasis, Pangasinan, and that they appropriated the entire harvest for the agricultural year 1960-61, refusing to deliver her lawful share. Tuvera filed an answer denying the tenancy relationship, claiming ownership of the land, and setting forth a counterclaim. During the trial, after Sanchez presented her evidence, the court ordered Tuvera and Marquez to submit a certified copy of the certificate of title in the name of their alleged predecessor-in-interest. Subsequently, on June 20, 1962, Tuvera and Marquez did not appear at the hearing. Their counsel filed a motion to dismiss, stating that they had filed a suit in the Court of First Instance of Pangasinan on March 15, 1962, asserting ownership of the land. The Agrarian Court, due to their non-appearance, considered the case submitted for decision based on the evidence on record and rendered judgment in favor of Sanchez, authorizing her to eject Tuvera and Marquez and appoint new tenants. The motion for reconsideration was denied.
ISSUE
Whether the filing of a separate suit in the Court of First Instance to litigate ownership of the land divested the Court of Agrarian Relations of its jurisdiction over the ejectment case.
RULING
No. The Court of Agrarian Relations retained jurisdiction. Jurisdiction is determined by the allegations in the complaint. Sanchez’s complaint alleged a landlord-tenant relationship and a cause of action for dispossession of a tenant, which falls under the exclusive original jurisdiction of the Court of Agrarian Relations pursuant to Section 21 of Republic Act No. 1199 and Section 7 of Republic Act No. 1267 . The jurisdiction of the Agrarian Court subsists even if the tenant denies the relationship and asserts ownership over the land. Furthermore, once a court has acquired jurisdiction over a case, it continues to have that jurisdiction until the case is terminated. The subsequent filing of an ownership suit in the Court of First Instance did not divest the Agrarian Court of its already acquired jurisdiction. The Supreme Court also found substantial evidence supporting the Agrarian Court’s finding that Tuvera and Marquez were tenants of Sanchez who deliberately failed to deliver her share, warranting ejectment under Section 50(c) of Republic Act 1199. The judgment of the Court of Agrarian Relations was affirmed.