G.R. No. L-4206 January 31, 1952
CASIANO DE LA CRUZ, ET AL., plaintiff-appellants, vs. JACOBO CAPULUNGAN, ET AL., defendants-appellees.

FACTS

The plaintiffs-appellants, owners of a tract of land in Bacarra, Ilocos Norte, entered into a tenancy contract with the defendants-appellees, whereby the latter were to irrigate and till the land. In a prior action, the Supreme Court sentenced the plaintiffs to pay damages for each agricultural season until the tenants (defendants) were allowed to return to work after having been excluded. After paying these damages, the plaintiffs notified the defendants to return to work, but the defendants refused. Consequently, the plaintiffs filed an action in the Court of First Instance of Ilocos Norte to rescind the tenancy contract and to claim damages. Before answering, the defendants filed a motion for a bill of particulars. The court denied the motion but, motu proprio, dismissed the case for lack of jurisdiction, holding that an action for rescission of a tenancy contract should be disposed of under Commonwealth Act No. 461 , as amended by Republic Act No. 44 . The plaintiffs appealed, contending the court erred in dismissing without allowing an amendment to the complaint and in holding it lacked jurisdiction, arguing that the cited Acts are unconstitutional.

ISSUE

Whether the Court of First Instance correctly dismissed the case for lack of jurisdiction, holding that the action for rescission of a tenancy contract falls under the exclusive jurisdiction of the Department of Justice as provided by Commonwealth Act No. 461 , as amended.

RULING

Yes, the order of dismissal is affirmed. The Supreme Court held that Commonwealth Act No. 461 , as amended, regulates landlord-tenant relations and provides for compulsory arbitration. Specifically, it states that a tenant shall not be dispossessed except for causes under section 19 of Act No. 4054 or for just cause, and without the approval of a Department of Justice representative. Following the precedent in Ojo et al. vs. Jamito et al., this grant of special jurisdiction to the Department of Justice to determine dispossession cases has taken that jurisdiction away from the general jurisdiction of the Courts of First Instance. The present action, aimed at rescinding the tenancy contract, would result in excluding the tenants from the land and thus falls squarely within the statute’s purview. The claim of unconstitutionality is untenable, as Congress has the power under the Constitution to define and apportion jurisdiction among courts, with the limitation that it cannot deprive the Supreme Court of its appellate jurisdiction. The appellants’ complaint about not being allowed to amend their complaint fails because they did not specify any amendment that would remove the case from the statute’s operation.