GR L 33293; (September, 1974) (Digest)
G.R. No. L-33293 September 30, 1974
DOMINGO FERRER, ET AL., petitioners, vs. HON. FLORENCIO VILLAMOR, Presiding Judge of the Court of First Instance, Nueva Ecija, PROVINCIAL SHERIFF of NUEVA ECIJA and SANTIAGO CAJUCOM, respondents.
FACTS
Private respondent Santiago Cajucom filed an ejectment complaint against petitioners in the Municipal Court of Lupao, Nueva Ecija, alleging the expiration of their lease contracts. Petitioners, in their answer, asserted they were agricultural lessees, thereby challenging the court’s jurisdiction and claiming exclusive jurisdiction vested in the Court of Agrarian Relations. The municipal court, however, proceeded with the trial, hearing only the respondent’s evidence after denying petitioners’ motion for postponement. It rendered a judgment ordering petitioners to vacate their homelots and remove their houses.
Petitioners appealed to the Court of First Instance of Nueva Ecija. During the pendency of this appeal, private respondent filed a motion for demolition. Respondent Judge Florencio Villamor granted the motion and authorized an alias writ of execution, leading petitioners to file this certiorari proceeding. They argued that the municipal court lacked jurisdiction from the outset, rendering all subsequent proceedings, including the writ, null and void.
ISSUE
Whether the municipal court and, consequently, the Court of First Instance on appeal, had jurisdiction over the ejectment case involving petitioners who claimed to be agricultural lessees.
RULING
The Supreme Court granted the writ of certiorari, nullifying the alias writ of execution. The Court held that the municipal court lacked jurisdiction. The legal logic is anchored on a long-standing and unbroken line of jurisprudence, beginning with Ojo v. Jamito, which established that jurisdiction over controversies between landowners and agricultural tenants or lessees is vested by law in specialized agrarian agencies, not the regular courts.
The constitutional mandate for social justice and protection to labor, embodied in the 1935 Constitution, led to the enactment of statutes like Commonwealth Act No. 461, which divested ordinary courts of jurisdiction over tenancy disputes and conferred it upon the Department of Justice and, later, the Court of Industrial Relations. This policy was reinforced by subsequent laws, including the Agricultural Tenancy Act ( Republic Act No. 1199 ) and the law creating the Court of Agrarian Relations ( Republic Act No. 1267 ), which granted said court original and exclusive jurisdiction over all cases involving agricultural tenancy. The Court emphasized that the jurisdiction of agrarian tribunals is determined by the nature of the relationship as alleged in the complaint and the relief sought. Since the ejectment case inherently involved a determination of an agricultural tenancy relationship—a matter beyond the competence of the municipal court—it acted without jurisdiction. Consequently, its judgment was void, and the Court of First Instance could not validate it on appeal or properly issue a writ of execution. The proceedings were a nullity from their inception.