G.R. No. L-27895 July 31, 1974
JOSE Y. AREVALO and CECILIO Y. AREVALO, JR., petitioners, vs. HON. MARIANO V. BENEDICTO, as Judge of the Court of First Instance of Nueva Ecija, and LUCIANO MATIAS, respondents.

FACTS

Petitioners Jose and Cecilio Arevalo, co-owners of a riceland, filed a forcible entry case against respondent Luciano Matias in the Municipal Court of Gapan. Matias claimed he was a tenant on the land, having worked it under a 50-50 sharing arrangement with the original lessee, Gertrudes Mangulabnan, since 1959. He argued the municipal court lacked jurisdiction because the case involved an agrarian dispute. The municipal court ruled for the Arevalos and ordered Matias to vacate. Matias filed a notice of appeal, but it was initially denied as pauper. The municipal court later reconsidered and forwarded the appeal to the Court of First Instance (CFI). The CFI, however, dismissed the appeal as filed out of time. Matias then filed a petition for relief from this dismissal order in the CFI.
Matias concurrently filed a separate complaint in the Court of Agrarian Relations (CAR) to prevent his ejectment, asserting his tenancy status. The CAR initially denied the Arevalos’ motion to dismiss but later dismissed Matias’s complaint on grounds of res judicata, citing the finality of the municipal court’s decision. Matias appealed this CAR dismissal to the Court of Appeals. Meanwhile, the CFI granted Matias’s petition for relief, finding his failure to perfect the appeal on time was due to excusable negligence (he attempted to file on a holiday and a closed Saturday). The CFI set aside its order dismissing the appeal and gave due course to it. The Arevalos then filed this certiorari petition to annul the CFI’s orders granting relief.

ISSUE

Whether the respondent Judge of the Court of First Instance acted with grave abuse of discretion in granting the petition for relief from the order dismissing the appeal.

RULING

No. The Supreme Court denied the petition. The core legal principle is that jurisdiction is conferred by law. The municipal court’s jurisdiction over the forcible entry case was contingent on the absence of a tenancy relationship. Since Matias explicitly raised the defense of tenancy, which, if true, would strip the municipal court of jurisdiction and vest it exclusively in the Court of Agrarian Relations, the municipal court was first obligated to resolve this jurisdictional question. A judgment rendered by a court without jurisdiction is void ab initio. A void judgment produces no legal effects, cannot become final or executory, and cannot constitute a valid basis for res judicata.
Therefore, the CFI’s act of granting relief to allow a determination on the merits of the appeal—which would include a review of the jurisdictional issue—was not a grave abuse of discretion. In fact, it served the interests of justice by preventing the enforcement of a potentially void judgment. The proper forum to determine the existence of tenancy, and thus jurisdiction, was the Court of Agrarian Relations (whose decision was already on appeal to the Court of Appeals). The Supreme Court’s dismissal of the certiorari petition effectively upheld the CFI’s order, allowing the appellate process to proceed and ensuring the jurisdictional question could be properly settled.