GR L 44337; (April, 1983) (Digest)
G.R. No. L-44337 April 28, 1983
ALEJANDRO DEPOSITARIO, petitioner-appellee, vs. CLAUDIO HERVIAS, respondent-appellant.
FACTS
Alejandro Depositario secured a money judgment from the Court of Agrarian Relations (CAR) against Claudio Hervias. After failing to satisfy the judgment via motion within five years, Depositario filed an action to revive the judgment in the City Court of Bacolod. Hervias moved to dismiss, arguing the City Court lacked jurisdiction as the claim arose from agrarian relations, which was under the CAR’s exclusive jurisdiction. The City Court agreed and dismissed the case.
Depositario then filed the same revival action with the CAR in Bacolod. Hervias completely reversed his legal position, now contending the CAR lacked jurisdiction. He argued that a revival action was a new, pure money claim based on a final judgment, not arising directly from agrarian relations. The CAR denied Hervias’s motion, assumed jurisdiction, and rendered a revival judgment in favor of Depositario. Hervias appealed, and the case was certified to the Supreme Court.
ISSUE
Did the Court of Agrarian Relations have jurisdiction over an action for the revival of its own final money judgment?
RULING
Yes, the CAR correctly exercised jurisdiction. The Supreme Court rejected Hervias’s appeal on two primary grounds. First, the doctrine of estoppel barred Hervias from taking inconsistent positions. He successfully argued for CAR’s exclusive jurisdiction in the City Court to secure a dismissal, then argued against that same jurisdiction in the CAR to avoid liability. This duplicity constituted a mockery of justice and a flaunting of good faith, which the Court would not tolerate.
Second, on the substantive jurisdictional question, the Court ruled that under the prevailing legislative policy embodied in the Agrarian Land Reform Code ( Republic Act No. 3844 ), the CAR had original and exclusive jurisdiction over all cases and money claims arising from agrarian relations. This grant of jurisdiction was sweeping and included all incidents related to such cases. Following precedent, an action to revive and enforce a CAR judgment is an incident of the original agrarian case. Therefore, jurisdiction properly remained with the CAR. The Court ordered the immediate issuance of a writ of execution to satisfy the long-pending judgment.