G.R. No. L-4019 July 31, 1951
TOMAS VILLANUEVA, MARIA REAL Y LUMANGLAS, RAMON REAL, JORGE CASCALLA, AND CRISANTA TOLENTINO, petitioners, vs. THE TENANCY LAW ENFORCEMENT DIVISION, DEPARTMENT OF JUSTICE, JUSTICE OF THE PEACE COURT OF LOBO, BATANGAS, in its capacity as representative of the said Tenancy Division, SABINO PUYO, LUIS MERCADO AND JOAQUIN HERRERA, respondents.

FACTS

Respondents Sabino Puyo, Luis Mercado, and Joaquin Herrera filed a complaint dated March 16, 1950, with the Tenancy Law Enforcement Division of the Department of Justice against petitioners Tomas Villanueva, Maria Real y Lumanglas, Ramon Real, Jorge Cascalla, and Crisanta Tolentino. They alleged a tenancy contract existed since May 1924 between them and petitioners Villanueva, Real y Lumanglas, and Real, which included a stipulation for compensation for fruit-bearing orange trees planted by the tenants if they left the landholdings. They further alleged that on October 4, 1948, petitioner Maria Real y Lumanglas sold the tenanted land to petitioners Jorge Cascalla and Crisanta Tolentino without the tenants’ knowledge. Cascalla and Tolentino took possession, ejecting the tenants without paying the stipulated price for the orange trees or the tenants’ share of the 1950 harvest. The complaint prayed for payment of P2,750 as half the price of the orange trees and P532 as the tenants’ share of the 1950 harvest. Petitioners filed a motion to dismiss, alleging the Tenancy Law Enforcement Division had no jurisdiction because the land was planted to orange trees, not rice or sugar, and thus not within the purview of Commonwealth Act No. 461 , as amended by Republic Act No. 44 . The justice of the peace of Lobo, Batangas, as representative of the Tenancy Division, denied the motion and a subsequent motion for reconsideration, prompting the petitioners to file the present petition for prohibition.

ISSUE

Whether the Tenancy Law Enforcement Division of the Department of Justice and the Justice of the Peace Court of Lobo, Batangas, as its representative, have jurisdiction over a tenancy dispute involving land planted to orange trees.

RULING

No. The Supreme Court granted the petition for prohibition and enjoined the respondents from taking cognizance of and further proceeding with the complaint. The Court held that the provisions of Commonwealth Act No. 461 , as last amended by Republic Act No. 44 , apply only to tenancies specifically covered by existing tenancy statutes. Citing its prior ruling in Arciga vs. De Jesus, the Court reasoned that the legislative intent, as explained by the sponsor of Republic Act No. 44 , was to extend the enforcement duty of the Department of Justice to cover all tenancy acts that have been or will be enacted. At the time, only two tenancy statutes had been enacted: the Rice Share Tenancy Act ( Act No. 4054 ) and the Sugar Tenancy Act ( Act No. 4113 ). Since there was no tenancy statute covering land planted to orange trees, the dispute did not fall under the jurisdiction of the agencies specified in Commonwealth Act No. 461 , as amended. The Court distinguished the case of Ojo vs. Jamito, cited by respondents, as that case involved a single contract covering both rice and coconut lands, and jurisdiction was sustained because the dispute involved rice land. An additional ground for granting the petition was that the complaint included as defendants Jorge Cascalla and Crisanta Tolentino, who were not parties to the alleged original tenancy contract, so there could be no tenancy dispute as to them.