G.R. No. L-34128 March 29, 1972
ABDON LAGMAN, petitioner, vs. COURT OF APPEALS, and HON. HONORIO ROMERO, as Presiding Judge, CFI-Pampanga, Branch III, RUSTICO TOBIAS as Deputy Sheriff of Pampanga, ISAAC CERVANTES, ENGRACIA CERVANTES, and RUFINO CERVANTES, respondents.

FACTS

Private respondents, the Cervantes family, filed an unlawful detainer complaint against petitioner Abdon Lagman in the Municipal Court of Macabebe, Pampanga. The municipal court dismissed the case, ruling it fell under the exclusive original jurisdiction of the Court of Agrarian Relations. Cervantes attempted to appeal, but the municipal judge dismissed the appeal for a P4 deficiency in docket fee payment. Cervantes then filed a special civil action for certiorari and mandamus (CFI Case No. 3573) against the judge and Lagman before the Court of First Instance (CFI) of Pampanga, presided by Judge Honorio Romero, to annul the dismissal and compel the appeal’s due course.
Judge Romero granted the petition, set aside the municipal court’s order, and gave due course to the appeal. By agreement, he decided the ejectment case based on the municipal court record. He subsequently rendered a decision in favor of Cervantes, ordering Lagman to vacate the land and pay rentals. Lagman moved for reconsideration, arguing the case was within the jurisdiction of the Court of Agrarian Relations, but the CFI proceeded to issue orders concerning the harvest of the palay crop. Lagman then filed a special civil action with the Court of Appeals, which dismissed his petition, leading to this review.

ISSUE

Whether the Court of First Instance (CFI) acquired jurisdiction over the unlawful detainer case on appeal.

RULING

No, the CFI did not acquire jurisdiction. The Supreme Court reversed the Court of Appeals. The core legal principle is that jurisdiction over the subject matter is conferred by law and determined by the allegations in the complaint. Cervantes’s complaint in the municipal court explicitly alleged a leasehold relationship over an agricultural land devoted to palay cultivation. Under Republic Act No. 1267, as amended, such tenancy relationships fall under the exclusive original jurisdiction of the Court of Agrarian Relations. Consequently, the municipal court correctly dismissed the case for lack of jurisdiction.
Since the municipal court had no jurisdiction over the subject matter, it could not validly render a decision. An appeal from a void judgment does not confer jurisdiction upon the appellate court. The CFI, acting as an appellate court, therefore acquired no jurisdiction to review, much less decide, the merits of the unlawful detainer case. Judge Romero’s decision was null and void. The Supreme Court emphasized that the challenge to jurisdiction could be raised at any stage, as jurisdiction is fundamental. The CFI’s error was compounded by improperly consolidating the original special civil action (certiorari) with the appealed ejectment case, which were distinct proceedings with different parties and issues. The writs prayed for by Lagman were granted.