G.R. No. L-65928 June 21, 1988
ANDERSON CO. AND JOSE CHU, petitioners, vs. THE HONORABLE INTERMEDIATE APPELLATE COURT, THE HONORABLE BIENVINIDO D. CHINGCUANGO AS PRESIDING JUDGE, and JOVENO ROARING, respondents.

FACTS

The dispute involves a parcel of agricultural land originally owned by Toribio Alarcon and leased to the Republic Broadcasting System (DZBB). Miguel Alfonso cultivated the land as an agricultural tenant until his death in 1976, after which his son-in-law, private respondent Joveno Roaring, took over. The property was later acquired by petitioner Anderson Co. from the Philippine Commercial and Industrial Bank, who then assigned his rights to co-petitioner Jose Chua. The petitioners demanded that Roaring vacate the property and, after failed settlement attempts, secured a demolition order from the National Housing Authority, resulting in the destruction of Roaring’s house on November 22, 1980. Roaring filed a complaint for maintenance of possession and damages. The agrarian court declared Roaring a tenant/agricultural lessee, ordered Chua to maintain him in peaceful cultivation, and held Co. and Chua solidarily liable for damages. The Intermediate Appellate Court affirmed the decision with modification, absolving another defendant from financial liability.

ISSUE

The primary issues are: (1) whether the trial court retained jurisdiction over the case despite a subsequent zoning ordinance reclassifying the area; and (2) whether the factual findings of the lower courts, which established Roaring’s status as a tenant, are binding.

RULING

The Supreme Court denied the petition. First, on jurisdiction, the Court ruled that Metro Manila Zoning Ordinance No. 81-01, which declared the area for residential or light industrial use, operates prospectively only. It does not retroactively discontinue existing rights over agricultural lands within the zone. While a zoning ordinance, as an exercise of police power, can affect existing legal relationships, the ordinance in question manifested no clear intent to impair the pre-existing agricultural leasehold right of Roaring. Jurisdiction is determined by the allegations in the complaint at the time of its filing, which invoked agrarian relations. The court’s jurisdiction, once validly acquired, is retained unless a subsequent law expressly provides otherwise. Second, the Court emphasized that the petition raised factual issues, which are not reviewable under a Rule 45 appeal limited to questions of law. The factual findings of the lower courts, amply supported by evidence, are conclusive. These findings established Roaring’s tenancy status through his and his father-in-law’s continuous cultivation, which was recognized even by the former lessee, DZBB. The petitioners failed to show any recognized exception to warrant a factual review. The award of damages was also upheld as a consequence of the unlawful demolition.