G.R. No. L-38206. March 25, 1975.
PABLO NONAN and CRISTETA ALCANTARA, petitioners, vs. HONORABLE ANDRES B. PLAN, IRENEO ABUAN and ANGEL MAGBALETA, respondents.

FACTS

Private respondents Ireneo Abuan and Angel Magbaleta initiated a special civil action in the Court of First Instance of Isabela, seeking a writ of possession against petitioners Pablo Nonan and Cristeta Alcantara. Respondent Judge Andres B. Plan granted the writ on January 15, 1973, but his order contained a crucial qualification: it was issued “without prejudice… to [petitioners] pursue their case now pending before the Court of Agrarian Relations.” This admission indicated an existing tenancy dispute between the parties over the same land.
Subsequently, petitioners failed to comply with the writ, leading to contempt proceedings. In their defense, filed on July 25, 1973, they asserted they were tenants protected from ejectment by Presidential Decree No. 27 and related issuances, which prohibited the dispossession of tenant-farmers pending implementing rules. In an order dated September 29, 1973, respondent Judge denied petitioners’ motion to set aside the contempt proceedings, even while acknowledging their defense was based on these protective tenancy decrees.

ISSUE

Whether the respondent Judge acted without jurisdiction or with grave abuse of discretion in issuing the writ of possession and in denying the motion to set aside contempt proceedings, despite the existence of a pending tenancy case and applicable agrarian reform laws.

RULING

The Supreme Court granted the petition for certiorari, nullifying the challenged orders. The legal logic is anchored on the exclusive jurisdiction over tenancy disputes. The Court emphasized that as early as 1939, regular courts have been divested of jurisdiction over agrarian or tenancy controversies, a policy consistently upheld. This jurisdiction is vested exclusively in the Court of Agrarian Relations.
The respondent Judge’s own orders revealed a fatal jurisdictional flaw. By acknowledging the pending tenancy case in the agrarian court and the applicability of Presidential Decree No. 27 (emancipating tenants), the lower court effectively recognized that the core issue—possession of the land—was intertwined with a tenancy relationship. Under the law, such a matter falls outside the jurisdiction of a regular court of first instance. The issuance of the writ of possession, and the subsequent contempt proceedings to enforce it, constituted an unlawful intrusion into the exclusive domain of the agrarian court.
Furthermore, the Court found the orders internally contradictory. They recognized the pending agrarian case and the protective mantle of agrarian reform decrees, yet proceeded to grant coercive relief that would effectively eject the alleged tenants. This was a grave abuse of discretion. Prudence and explicit legal mandate required the respondent Judge to defer to the pending proceedings in the Court of Agrarian Relations and to respect the statutory prohibition against ejecting tenants pending the implementation of the agrarian reform program. Consequently, the respondent Judge was declared devoid of jurisdiction to proceed with the special civil action.