GR L 8702; (April, 1956) (Digest)
G.R. No. L-8702; April 28, 1956
VICENTE BASILIO, petitioner, vs. ZOILO DAVID, VICENTA DAVID, AMPARO DAVID, ESTELITA DAVID and LADISLAO DAVID, respondents.
FACTS
On September 3, 1954, respondents filed a complaint for forcible entry against petitioner Vicente Basilio in the Justice of the Peace Court of Santa Rita, Pampanga, seeking to recover possession of four parcels of land. In his answer dated September 13, 1954, Basilio asserted, as an affirmative defense, that the case involved a landlord-tenant relationship and therefore the Justice of the Peace Court lacked jurisdiction. Despite this objection, the court proceeded, and on October 20, 1954, rendered a judgment ordering Basilio to: (1) vacate the land; (2) pay 130 cavans of palay or its equivalent (P1,040) as the respondents’ share; (3) pay P100 as attorney’s fees; and (4) pay costs. Basilio appealed to the Court of First Instance (CFI). On December 2, 1954, he filed a motion to dismiss/suspend proceedings in the CFI, arguing that tenancy cases fall under the exclusive jurisdiction of the Court of Industrial Relations pursuant to Republic Act No. 1199 (Agricultural Tenancy Act). On December 27, 1954, the CFI, upon respondents’ motion, ordered execution of the Justice of the Peace Court’s judgment due to Basilio’s failure to pay the adjudged amount or file a supersedeas bond. Basilio filed a pauper’s petition for certiorari to annul both the judgment and the execution order. He also filed a petition with the Court of Industrial Relations on November 3, 1954, seeking resolution of the tenancy dispute.
ISSUE
Whether the Justice of the Peace Court and the Court of First Instance had jurisdiction over the case, given the petitioner’s claim of a landlord-tenant relationship.
RULING
The Supreme Court granted the writ of certiorari. It held that when the evidence presented showed the petitioner’s grandfather had possessed the land for many years and the petitioner himself had worked on it since age fifteen, and considering the respondents’ prayer for a share of the produce, a tenancy relationship was established by preponderance of evidence. Under Section 21 of Republic Act No. 1199 , all cases involving dispossession of a tenant and disputes arising from landlord-tenant relationships fall under the original and exclusive jurisdiction of the Court of Industrial Relations. Therefore, the Justice of the Peace Court should have dismissed the complaint for lack of jurisdiction. The Court noted a procedural defect—the failure to implead the lower courts as respondents—but allowed an amendment to cure it. The decision of the Justice of the Peace Court dated October 20, 1954, and the order of the Court of First Instance dated December 27, 1954, were annulled.