PEDRO GABANI, ET AL., PETITIONERS AND APPELLEES, VS. JUAN E. REAS, ET AL., RESPONDENTS AND APPELLANTS.

Gabani versus Reas

The Case

This is a petition for certiorari brought by Pedro Gabani and his co-tenants against Juan Reas, their landholder, and the justice of the peace of Wright, Samar. The tenants asked the Court of First Instance of Samar to annul, as void for want of jurisdiction, the judgment of the justice of the peace court in an unlawful detainer case that ordered them to pay rentals, damages, and attorney's fees, and to vacate the land. The case matters because it fixes the dividing line between ordinary ejectment courts and the special tenancy courts: where the relationship between the parties is agricultural tenancy, jurisdiction lies exclusively with the Court of Agrarian Relations, and a justice of the peace court that takes cognizance of such a case acts without jurisdiction.

Procedural History

Juan Reas filed an action styled unlawful detainer against Pedro Gabani, Eustaquio Orabiles, Alejandro Obina, and Claro Obidos in the Justice of the Peace Court of Wright, Samar. The defendants moved to dismiss on the ground that the court lacked jurisdiction; the motion was denied, they answered, and after hearing the inferior court rendered judgment against them. The defendants then filed a special civil action for certiorari in the Court of First Instance of Samar against Reas and the justice of the peace, praying that the judgment be declared null and void and that Reas be condemned to pay moral damages and attorney's fees. The respondents moved to dismiss the petition, the motion was denied, and after hearing the Court of First Instance rendered judgment declaring the justice of the peace decision null and void and condemning Reas to pay damages and attorney's fees. Reas appealed to the Supreme Court, which resolved the appeal on the single dominant question of whether the trial court correctly annulled the justice of the peace decision for lack of jurisdiction.

Facts

In May 1956, the defendants contracted with Juan Reas to plant rice and corn on his properties, under the condition of paying a yearly rental of one and one-half sacks of palay and corn, valued at eight pesos per sack of palay and five pesos per sack of corn. The defendants forthwith began planting and had been harvesting the products up to the time of the complaint, but they did not pay the agreed rentals despite repeated demands.

Because of their failure and refusal to pay or to vacate the land, Reas instituted the unlawful detainer action in the Justice of the Peace Court of Wright, Samar, praying that the defendants be ordered to pay rentals in palay and corn for 1955 and 1956, plus interest, to vacate the land, and to pay damages and attorney's fees.

The justice of the peace court rendered judgment ordering each defendant to give as rentals three sacks of palay and three sacks of corn for the years 1955 and 1956, or thirty-nine pesos each, a total of one hundred fifty-six pesos, to pay interest, to vacate the land and restore possession to the plaintiff, and to pay two hundred pesos as damages and three hundred pesos as attorney's fees. The defendants could not furnish the five hundred peso bond fixed by the inferior court to stay execution, so execution issued and a notice of attachment was filed with the Register of Deeds. The tenants then brought the certiorari action in the Court of First Instance of Samar.

Issues

• Whether or not the justice of the peace court had jurisdiction to take cognizance of the unlawful detainer case, or whether jurisdiction belonged exclusively to the Court of Agrarian Relations.
• Whether or not the Court of First Instance correctly annulled the decision of the justice of the peace for lack of jurisdiction.

Applicable Provisions

Section 4 of the Agricultural Tenancy Act, as amended, defines the systems of agricultural tenancy:

Section 4. Systems of Agricultural Tenancy; Their definitions—Agricultural Tenancy is classified into leasehold tenancy and share tenancy. Share tenancy exists when one who, personally or with the aid of labor available from members of his immediate farm household, undertakes to cultivate a piece of agricultural land susceptible of cultivation by a single person together with members of his immediate farm household, belonging to or legally possessed by another, in consideration of a share of the crops. Leasehold Tenancy exists when a person who, either personally or with the aid of labor available from members of his immediate farm household, undertakes to cultivate a piece of agricultural land susceptible of cultivation by a single person together with members of his immediate farm household, belonging to or legally possessed by another in consideration of a price certain or ascertainable to be paid by the person cultivating the land either in percentage of the production or in a fixed amount in money, or both.

This definition brings the relationship between Reas and the tenants within leasehold tenancy, since the tenants cultivated the land for a fixed rental in palay and corn.

Section 21 of the same Act fixes the jurisdiction over ejectment of tenants:

Section 21. Ejectment; Violation; Jurisdiction.—All cases involving the dispossession of a tenant by the landholder or by a third party and/or the settlement and disposition of disputes arising from the relationship of landholder and tenant, as well as the violation of any of the provisions of this Act, shall be under the original and exclusive jurisdiction of such court as may now or hereinafter be authorized by law to take cognizance of tenancy relations and disputes.

This provision removes from the justice of the peace court all cases of dispossession of a tenant by the landholder and vests jurisdiction exclusively in the tenancy court.

Section 7 of Republic Act Number 1267 identifies that court:

Section 7. Jurisdiction of the Court.—The Court shall have original and exclusive jurisdiction over the entire Philippines, to consider, investigate, decide, and settle all questions, matters, controversies, or disputes involving all those relationships established by law which determine the varying rights of persons in the cultivation and use of agricultural land where one of the parties works the land, and shall have concurrent jurisdiction with the Court of First Instance over the employer and farm employees or labor under the Republic Act numbered Six Hundred Two (Minimum Wage Law), and over landlord and tenant involving violations of the Usury Law (Act No 2655) as amended, and of inflicting the penalties provided therefor.

This provision confirms that the Court of Agrarian Relations is the court authorized by law to take cognizance of tenancy relations and disputes.

Ruling

On the first issue, the Court held that the justice of the peace court had no jurisdiction. The complaint itself alleged that the defendants contracted to plant rice and corn on the properties in consideration of a yearly rental of palay and corn, and the Court found that the causes of action described a leasehold tenancy: a case of dispossession or ejectment of a tenant by the landlord of agricultural land where the tenant cultivates or works the land in consideration of a price certain paid by the one cultivating it, consisting of so many sacks of rice and corn as rentals. The Court stressed that the tenancy laws are clear and definite as to what court should take cognizance of disputes arising from such relationship, and that Section 21 says all cases involving the dispossession of a tenant by the landholder shall be under the original and exclusive jurisdiction of such court as may be authorized by law to take cognizance of tenancy relations and disputes, which, by virtue of Section 7, is the Court of Agrarian Relations.

On the second issue, the Court held that the Court of First Instance acted correctly in annulling the decision of the justice of the peace for lack of jurisdiction. Having reached that conclusion, the Court found it unnecessary to pass upon the other minor issues raised by the respondents-appellants.

Doctrine

All cases involving the dispossession of a tenant by the landholder, and all disputes arising from the relationship of landholder and tenant, fall within the original and exclusive jurisdiction of the Court of Agrarian Relations, not the justice of the peace court. Where the complaint alleges a leasehold tenancy, meaning cultivation of agricultural land in consideration of a price certain or ascertainable paid in a percentage of production or a fixed amount in money, or both, the case is a tenancy dispute regardless of the label the plaintiff gives it. A judgment rendered by a court without jurisdiction is null and void, and certiorari lies to annul it.

Disposition

The Supreme Court affirmed the decision of the Court of First Instance of Samar, with costs against the respondents-appellants; the tenants won, and the justice of the peace judgment was declared null and void.

Remember This

The single line worth memorizing is that the dispossession of an agricultural tenant by his landholder belongs exclusively to the Court of Agrarian Relations, and a justice of the peace court that tries it acts without jurisdiction. Examiners use this case to test jurisdiction over tenancy disputes and the rule that jurisdiction is determined by the allegations of the complaint, not by its title.