G.R. No. L-24241 February 26, 1968
Hatib Abbain, petitioner-appellant, vs. Tongham Chua, et al., respondents-appellees.

FACTS

On March 12, 1958, respondent Tongham Chua filed a complaint for “forcible entry and illegal detainer” against petitioner Hatib Abbain with the Justice of the Peace Court of Bongao, Sulu. Chua alleged he was the owner of a coconut plantation donated by his father, that Abbain was his tenant on a 50-50 sharing basis, and that Abbain, by force and strategy, unlawfully entered and occupied the land in December 1957, refusing to vacate and to give Chua’s share of the harvests. On February 27, 1959, the Justice of the Peace Court rendered judgment in favor of Chua, ordering Abbain to vacate. The court found that Abbain had sold the plantation to Chua’s father before WWII, became a tenant, and after the donation, continued as tenant for Chua, but later refused to give the landlord’s share. On June 30, 1959, Abbain filed a petition in the Court of First Instance of Sulu seeking relief from and/or annulment of the Justice of the Peace Court’s decision, alleging lack of jurisdiction as the case involved a landlord-tenant dispute falling under the exclusive original jurisdiction of the Court of Agrarian Relations, and that fraud, mistake, or excusable negligence deprived him of a hearing and appeal. On October 30, 1964, the CFI dismissed the petition, finding no evidence of fraud or negligence preventing a hearing or appeal, and ruled that Abbain failed to prove a landlord-tenant relationship to place the case under the Court of Agrarian Relations’ jurisdiction, holding the case was “clearly one of ejectment.”

ISSUE

Whether the Justice of the Peace Court had jurisdiction over the ejectment case, given the allegations and findings of a landlord-tenant relationship.

RULING

No. The Supreme Court reversed the CFI order and annulled the decision of the Justice of the Peace Court. The complaint itself and the inferior court’s findings explicitly established a landlord-tenant relationship between the parties, with Abbain as tenant on a 50-50 sharing basis. Under Section 21 of Republic Act 1199 (Agricultural Tenancy Act) and Section 7 of Republic Act 1267 (creating the Court of Agrarian Relations), all cases involving the dispossession of a tenant by the landholder fall under the original and exclusive jurisdiction of the Court of Agrarian Relations. Since the case was filed in 1958, long after these laws took effect, the Justice of the Peace Court had no jurisdiction. Its judgment was void ab initio and could be attacked directly at any time, making the time limits for relief under Rule 38 inapplicable. The proceedings and judgment were declared null and void.