QUIRINO DUMLAO, ET AL., PETITIONERS VS. HON. PASTOR L. DE GUZMAN, ETC., ET AL., RESPONDENTS.

Dumlao versus De Guzman

The Case

This is a petition for review on certiorari brought by Quirino Dumlao and his co-petitioners against the Honorable Pastor L. De Guzman, in his capacity as Judge of the Court of Agrarian Relations, and against the Farrales group, who were the respondents below. The petitioners ask the Supreme Court to reverse a decision of the Court of Agrarian Relations which found that the respondents had been illegally dispossessed of their landholdings and ordered their immediate reinstatement as tenants. The case matters because it draws the boundary of the agrarian court's jurisdiction: the security of tenure granted by the Tenancy Law belongs only to a true tenant, one whose tenancy was created with the consent of the real landholder, and where no valid tenancy relation exists, the agrarian court has no jurisdiction at all.

Procedural History

The story begins in the Justice of the Peace Court of San Narciso, Zambales, in a forcible entry and detainer case filed by Epifanio Farrales against the petitioners. That court dismissed the complaint, ordered Epifanio Farrales to surrender possession to the defendants, and awarded damages and costs. Epifanio Farrales appealed to the Court of First Instance of Zambales, but the appeal was dismissed for having been filed out of time. Execution followed, and the petitioners were restored to possession. Epifanio Farrales then challenged the writ of execution in a petition for certiorari with preliminary injunction before the Court of First Instance, which dismissed the petition and denied reconsideration.

Meanwhile, the Farrales respondents filed a petition for reinstatement with damages before the Court of Industrial Relations, later transferred to the Court of Agrarian Relations. After hearing, the agrarian court found them illegally dispossessed and ordered their reinstatement, directed the petitioners to vacate the premises, and awarded attorney's fees. Reconsideration was denied, and the petitioners came to the Supreme Court by petition for review.

Facts

Epifanio Farrales had constituted the respondents as tenants on their respective landholdings. But in the forcible entry and detainer case, the justice of the peace court held against him, and that decision became final and executory when his appeal was dismissed for tardiness. By virtue of the writ of execution, the sheriff, aided by policemen, restored the petitioners to possession of the land.

The respondents then claimed they had been illegally dispossessed of their holdings, demanding reinstatement and damages consisting of palay and attorney's fees. The Court of Agrarian Relations ruled in their favor, finding illegal dispossession and ordering reinstatement.

The Supreme Court noted that it was undisputed the respondents were dispossessed by virtue of a writ of execution enforcing a decision that had already become final, and that they had been made tenants by Epifanio Farrales, who was himself ejected from the land by court order.

Issues

• Whether or not the respondents, who were constituted as tenants by a supposed landholder later held to be an unlawful intruder, may invoke the security of tenure under the Tenancy Law.
• Whether or not the Court of Agrarian Relations acquired jurisdiction over the case absent a valid tenancy relation between the parties.
• Whether or not the pendency of annulment proceedings against the final decision of the justice of the peace court affects the finding of lack of jurisdiction.

Applicable Provisions

Section 5, paragraph b, of Republic Act Number 1199, the Tenancy Law, provides:

Tenancy relation can only be created with the consent of the true landholder who is either the owner, lessee, usufructuary, or legal possessor of the land.

This provision is decisive because the respondents' tenancy was created not by the true landholder but by Epifanio Farrales, who had no right to the landholdings.

Ruling

On the first issue, the Court held that the security of tenure guaranteed by the Tenancy Law may be invoked only by tenants de jure, meaning true and lawful tenants, and not by those who became tenants only through the acts of a supposed landholder who had no right to the land. Since Epifanio Farrales had in effect been held to be an unlawful squatter and intruder, the respondents cannot claim that the petitioners are legally bound to maintain them as tenants.

On the second issue, the Court held that there being no valid tenancy relation between the respondents and their former landholder, the petitioners, who had been declared lawful possessors of the land, cannot be compelled to retain them as tenants. And there being no tenancy relation between the parties, it is obvious that the Agrarian Court acquired no jurisdiction over the case.

On the third issue, the Court held that the pendency of annulment proceedings against the decision of the justice of the peace court is of no legal consequence. Such a decision, until actually voided, is valid and binding upon the parties. Besides, whatever the outcome of the annulment proceedings, the fact remains that the respondents are not, and have never been, the petitioners' tenants.

Doctrine

The security of tenure under the Tenancy Law belongs only to a tenant de jure, a true and lawful tenant. A tenancy relation can be created only with the consent of the true landholder, who is the owner, lessee, usufructuary, or legal possessor of the land. One who becomes a tenant only through the acts of a supposed landholder who had no right to the land is not a true tenant and cannot invoke that security of tenure. Where no valid tenancy relation exists between the parties, the Court of Agrarian Relations acquires no jurisdiction over the controversy. A final and executory decision remains valid and binding until actually voided, and the pendency of annulment proceedings does not defeat a finding of lack of jurisdiction.

Disposition

The Court reversed and set aside the decision of the Court of Agrarian Relations, with costs against the respondents except the respondent Judge of the Agrarian Court. The petitioners won.

Remember This

Memorize this line: the security of tenure under the Tenancy Law may be invoked only by a tenant de jure, never by one whose tenancy came from a landholder with no right to the land. Examiners use this case to test jurisdiction of the agrarian court and the requisites of a valid tenancy relation, especially the consent of the true landholder.