JOSE Y. AREVALO AND CECILIO Y. AREVALO, JR., PETITIONERS, VS. HON. MARIANO V. BENEDICTO, AS JUDGE OF THE COURT OF FIRST INSTANCE OF NUEVA ECIJA, AND LUCIANO MATIAS, RESPONDENTS.

Arevalo versus Benedicto

The Case

This is a special civil action for certiorari and prohibition, with a prayer for preliminary injunction, brought by the Arevalo brothers against Judge Mariano Benedicto of the Court of First Instance of Nueva Ecija and against Luciano Matias. The Arevalos ask the Supreme Court to set aside the trial court's orders granting Matias relief from judgment and giving due course to his appeal in a forcible entry case. The case matters because it teaches the boundary between a forcible entry action and a tenancy dispute, and because it declares that a judgment rendered without jurisdiction over the subject matter is void and can never bar another case by res judicata.

Procedural History

The Arevalos filed a complaint for forcible entry with the Municipal Court of Gapan. Matias, claiming to be a tenant, filed a separate complaint with the Court of Agrarian Relations of Cabanatuan City to prevent his ejectment. The municipal court rendered judgment in favor of the Arevalos. Matias's appeal was dismissed by the Court of First Instance of Nueva Ecija, Branch Five, on the ground that it was filed beyond the fifteen-day reglementary period. Matias then filed a petition for relief from that order of dismissal. The trial court granted the relief, gave due course to the appeal, and set the case for pre-trial and trial. The Arevalos moved for reconsideration, but the motion was denied. Meanwhile, the Court of Agrarian Relations dismissed Matias's agrarian complaint on the ground of res judicata, and Matias appealed that dismissal to the Court of Appeals. The Arevalos then came to the Supreme Court by this original action for certiorari and prohibition.

Facts

Jose and Cecilio Arevalo are brothers and co-owners of a three and a half hectare riceland in Pambuan, Gapan, Nueva Ecija. In 1956 they verbally leased the land to Gertrudes Mangulabnan. When her husband died in 1958, she hired other persons to help work the land, and among them was Luciano Matias. In 1959 a fifty-fifty sharing arrangement was made between Gertrudes and Matias, and this continued until she returned the land to the Arevalos after the harvest in March 1966.

The Arevalos refused to recognize Matias as their tenant and told him to vacate. When he refused, they filed a forcible entry action against him with the Municipal Court of Gapan on March 29, 1966. Matias, through the Office of the Agrarian Counsel, filed a complaint with the Court of Agrarian Relations to prevent his ejectment, claiming that he remained a tenant even after Mangulabnan's lease ended. The Arevalos moved to dismiss that complaint, but the motion was denied.

On July 25, 1966, the municipal court rendered judgment for the Arevalos. Matias received the decision on August 4, 1966, and filed his notice of appeal and related papers on August 22, 1966. He explained that he had gone to the municipal court on August 19, a special holiday, and again on August 20, a Saturday, but the offices were closed both times. The municipal court first denied his motion to appeal as pauper, then reconsidered and gave due course to the appeal. The Court of First Instance, however, dismissed the appeal as filed out of time. Matias then filed a petition for relief, which the trial court granted, finding that accident and excusable negligence had prevented him from perfecting his appeal on time.

Issues

• Whether or not the Municipal Court of Gapan had jurisdiction to decide the forcible entry case when the defendant pleaded a tenancy relationship.
• Whether or not the Court of First Instance committed grave abuse of discretion in granting Matias's petition for relief.
• Whether or not the dismissal of Matias's agrarian complaint on the ground of res judicata was correct.

Applicable Provisions

Section 9 of Republic Act 1199, as amended by Section 3 of Republic Act 2263, governs the effect of the return of leased land on the tenant:

Section 9. Termination of leasehold. The tenancy relationship is not extinguished by the transfer of legal possession of the land, and the tenant shall have the right to continue working on the land until the termination of the leasehold.

This provision is the basis of the rule that the tenant of the lessee keeps his right to remain on the land even after the lessee returns it to the owner.

Section 154 of Republic Act 3844, as amended by Republic Acts 4366 and 4886, the Agricultural Land Reform Code, defines the jurisdiction of the Court of Agrarian Relations:

Section 154. Jurisdiction of the Court of Agrarian Relations. The Court of Agrarian Relations shall have original and exclusive jurisdiction over all cases involving the violation of any provision of this Code.

This provision is decisive because the question of whether a tenant violated the Agricultural Land Reform Code belongs exclusively to the Court of Agrarian Relations, not to a municipal court.

Ruling

On the first issue, the Court held that although the complaint was ostensibly one for forcible entry, the trial showed it was in reality an action to dispossess a tenant of his agricultural landholding. The municipal court itself found that Matias was a share-tenant from 1959 until after the harvest in March 1966. Under the rule in Joya versus Pareja, the return of the land by the lessee to the lessor does not extinguish the tenancy, because the tenancy relationship is not extinguished by the transfer of legal possession. To avoid that doctrine, the municipal court concluded that Mangulabnan had sub-leased the property in violation of Section 27, paragraph 2, of the Agricultural Land Reform Code. But the Court held that whether a tenant has violated the Code is a matter within the original and exclusive jurisdiction of the Court of Agrarian Relations. Therefore, the municipal court's decision ordering Matias's ejectment was legally ineffective, having been rendered without jurisdiction over the subject matter.

On the second issue, the Court held that granting the petition for relief was not an abuse of discretion. The relief would enable the court to correct a patent error committed by the inferior court in assuming jurisdiction over the case.

On the third issue, the Court held that the agrarian court's ruling of res judicata was incorrect. The dismissal of the appeal could not make the municipal court's decision final, because the petition for relief was granted shortly after the agrarian court's order. More fundamentally, the Court declared that want of jurisdiction over the subject matter renders a judgment void and a mere nullity, and a void judgment cannot constitute a bar to another case by reason of res judicata.

Doctrine

A municipal court has no jurisdiction over a case that is in reality an action to dispossess an agricultural tenant, and any judgment it renders is void. The question of whether a tenant violated the Agricultural Land Reform Code falls within the original and exclusive jurisdiction of the Court of Agrarian Relations under Section 154 of Republic Act 3844. The tenancy relationship is not extinguished by the transfer of legal possession of the land under Section 9 of Republic Act 1199, as amended. Finally, a void judgment is in legal effect no judgment, it divests no rights and bars no one, and it can never become executory or serve as a bar by res judicata.

Disposition

The Supreme Court denied the petition, with costs against the Arevalos, and dissolved the writ of preliminary injunction previously issued.

Remember This

The single line to memorize is that a void judgment is no judgment at all, so it can never be a bar by res judicata. Examiners use this case to test jurisdiction over tenancy disputes and the rule that a judgment rendered without jurisdiction over the subject matter is a nullity.