G.R. No. L-7373. December 22, 1954
BENITO MENDOZA, PETITIONER, VS. J.M. MANGUIAT, MUNICIPAL JUDGE OF THE CITY OF LIPA, RESPONDENT.
LABRADOR, J.:
Lipa City from taking cognizance of a case therein designated as
“Tenancy Case No. 3,” and entitled “Francisco Macarandang versus Benito Mendoza.” Said “tenancy” case was filed on October 31, 1953. In his
complaint Macarandang alleged that Benito Mendoza is cultivating a
certain parcel of land belonging to Macarandang, which is planted to
citrus. Mendoza did not like to take care of the citrus trees planted
thereon by Macarandang, but he was to raise thereon diverse crops, like
palay, corn and other short-lived crops. As a ground of action, it is
alleged that inspite of the fact that Macarandang had given Mendoza
notice that he (Macarandang) was to plant vines and other cover crops
on the farm, Mendoza plowed half of it and, through carelessness,
destroyed 56 citrus trees.
Mendoza, through counsel, moved to dismiss the action, on the ground that the Court of Industrial Relations has jurisdiction to hear and decide the said case and that
the municipal court is without right to do so. The motion was denied on
the authority of the decision of this Court in the case of Arciga vs.
De Jesus, G.R. No. L-2003, promulgated on January 28, 1950. We held in
said case that (at the time) no tenancy law had been promulgated
governing the relations of the owner land the tenant of a coconut land.
We have confirmed our ruling in that case in the recent case of Vibal vs. Roldan, G.R. No. L-5138, promulgated October 24, 1952.
But since then, and more specifically on August 30, 1954, Republic
Act No. 1199 entitled “An Act to Govern the Relations between
Landholders and Tenants of Agricultural lands (Leasehold and Share
Tenancy)” has been approved. This law governs the relations between
landlord and tenant in all kinds of agricultural lands. It repeals C.A. No. 454) known as the Rice Share Tenancy Act, and C.A. 461. The
provisions of the Act are made to apply to all kinds of agricultural
lands, whatever may be their nature or character, whether rice, sugar,
corn or coconut, and as all controversies between landlord and tenant
are placed within the jurisdiction of the Court of Industrial
Relations, so any controversy between landlord and tenant, or owner and
lessee falls under said court’s jurisdiction.
So that at the time of the institution of the tenancy case in the
municipal court of Lipa City on October 31, 1953, said court,
therefore, still had jurisdiction to try the case, inasmuch as no law
on tenancy had yet been passed governing citrus lands; the case was not
yet cognizable by the Court of Industrial Relations, a court of special
jurisdiction. But, upon approval of Republic Act No. 1199, the relation
between the landowner and the tenant of the citrus land fell under, the
regulatory provisions of the Act; as a consequence, the power of the
municipal court to try and decide the case was revoked and transferred
to the Court of Industrial Relations. The jurisdiction that was
terminated is one over the subject-matter (not like the power in a
criminal case to try the case by virtue of the fact that the place
where the offense committed was within the territorial limits of the
court’s jurisdiction). The said case should, therefore, be, as it
hereby is dismissed, and the plaintiff therein directed to file his
action in the Court of Industrial Relations.
The petition for prohibition is hereby granted, without costs.
Paras, C.J., Pablo, Bengzon, Padilla, Montemayor, Reyes, A., Jugo, Bautista Angelo, Concepcion, and Reyes, J.B.L. JJ., concur.