GARCIA SAMSON, PLAINTIFF AND APPELLANT, VS. RAMON ENRIQUEZ AND FERMIN FILOTEO, DEFENDANTS AND APPELLEES.

Garcia Samson versus Ramon Enriquez and Fermin Filoteo

The Case

This is an action for forcible entry and detainer brought by Garcia Samson against Ramon Enriquez and Fermin Filoteo over a parcel of land in Zamboanga City, known as Lot Number 422. Samson claims a right to possess the land under a contract of tenancy, a contrato de aparceria, entered into in 1913, and complains that the defendants took the land from him by force and intimidation in April 1955. The defendants answer that Samson was a mere cropper whose right lasted only from planting to harvest, and that the true controversy is an agrarian tenancy dispute. The case matters because it fixes where the line falls between the municipal court's jurisdiction over forcible entry and the Court of Agrarian Relations' jurisdiction over tenancy disputes involving a system of cultivation.

Procedural History

Samson filed a verified complaint in the Municipal Court of Zamboanga City, together with an application for a writ of preliminary injunction. The municipal court issued the writ, later dissolved it upon the defendants' counterbond, and then, after hearing, rendered judgment holding that a tenancy relation existed between the parties and that their controversy involved a system of cultivation of an agricultural parcel of land. On that ground it declared itself without jurisdiction and transmitted the case to the Court of Agrarian Relations. Acting on the suggestion of the Court of Agrarian Relations, the municipal court dismissed the complaint.

Samson appealed to the Court of First Instance of Zamboanga, which held that the case was one for forcible entry over which the municipal court had jurisdiction, and remanded it. The municipal court then rendered judgment for Samson, ordering the defendants to vacate the land and deliver possession, to pay actual damages, attorney's fees, and costs, declaring the writ of preliminary injunction final, and dismissing the counterclaims. The defendants appealed to the Court of First Instance, which held that Samson was a mere cropper who tilled the land but did not divest the owners of their right to enter and take possession, that if he insisted on a right of possession under a contract of tenancy his remedy lay in the Court of Agrarian Relations, and that the Court of First Instance had no jurisdiction. It dismissed the appeal. Samson then appealed to the Supreme Court on the question of jurisdiction only.

Facts

Sometime in 1913, Jose Borja, now deceased, acting in his own behalf and as general attorney-in-fact of his co-owners, entered into a contract of tenancy with Garcia Samson over Lot Number 422. Under that contract Samson was to clear and prepare the land for planting palay at his own account and risk, using his own work animals and farm implements, and was to pay the owners twenty-five cavanes of palay annually at harvest. Samson avers that from 1913 until 13 April 1955 he was in peaceful possession of the land.

On 13 April 1955, according to Samson, the defendants entered the land by means of force, intimidation, threat, strategy or stealth and deprived him of possession. He further alleges that on 13 and 23 April and 2 and 3 June 1955 the defendants cut and destroyed two bamboo groves he had planted, causing damage, and that they refused to restore possession to him.

The defendants deny these averments. They say Samson had no written contract with the owners and never acquired possession; that he was a mere cropper whose right to stay and share in the harvest lasted only from planting to harvesting, or on a year to year basis; that Fermin Filoteo, not Jose Borja, was in charge of the land, and Samson paid him the abono, the rental or share; that in March 1955 Filoteo notified Samson in writing terminating his services as cropper and engaged Ramon Enriquez in his place; and that Samson had never made any permanent improvement on the land. The defendants also set up a counterclaim for moral damages and attorney's fees.

Issues

• Whether or not the Municipal Court of Zamboanga City had jurisdiction over the complaint, or whether jurisdiction lay with the Court of Agrarian Relations because the controversy involves a system of cultivation of an agricultural parcel of land.
• Whether or not Samson, claiming the right to possess the land under a contract of tenancy, must seek redress in the Court of Agrarian Relations rather than in the municipal court on a complaint for forcible entry.

Applicable Provisions

Section 7 of Republic Act Number 1267, as amended, is the provision the municipal court invoked when it declared itself without jurisdiction and transmitted the case to the Court of Agrarian Relations. The decision refers to it as the authority for that transmission, and it bears on the case because it marks the boundary between the agrarian court and the regular courts.

Section 7 of Republic Act Number 1267, as amended, governs the transmission of cases involving a system of cultivation to the Court of Agrarian Relations.

The decision also treats Republic Act Number 1199, the Tenancy Act, as amended, as the law governing controversies between landlord and tenant involving a system of cultivation, which the defendants invoked in their motion to dismiss before the Court of First Instance.

Ruling

On the first issue, the Court held that the municipal court was without jurisdiction. The complaint itself avers that Samson is entitled to the possession of the parcel of land under a contract of tenancy, a contrato de aparceria. The Court put the point plainly:

He alleges unequivocably that he is entitled to the possession of the parcel of land under a contract of tenancy (contrato de aparceria). Such being the case the Court of Agrarian Relations has jurisdiction of the case.

On the second issue, the Court held that Samson's claim of a right to possess under a contract of tenancy removes the case from the municipal court's forcible entry jurisdiction and places it within the Court of Agrarian Relations. The Court affirmed the order of the Court of First Instance dismissing the appeal, without pronouncement as to costs.

Doctrine

A plaintiff's own allegations determine the nature of the action and the court that has jurisdiction. Where the complaint unequivocally asserts a right to possess an agricultural parcel of land under a contract of tenancy, the controversy involves a system of cultivation and falls within the jurisdiction of the Court of Agrarian Relations under Republic Act Number 1267, as amended, and not within the municipal court's jurisdiction over forcible entry and detainer. A party cannot clothe his action in the form of forcible entry while grounding his right of possession on a tenancy contract; the agrarian court, not the regular court, is the proper forum.

Disposition

The Supreme Court affirmed the order of the Court of First Instance dismissing Samson's appeal, without pronouncement as to costs, leaving Samson to seek redress in the Court of Agrarian Relations.

Remember This

The single line to memorize is that a plaintiff who unequivocally claims possession under a contract of tenancy has placed his case within the jurisdiction of the Court of Agrarian Relations, not the municipal court. Examiners use this case to test jurisdiction over agrarian disputes and the rule that the allegations of the complaint, not the label of the action, determine which court may hear it.