ANTONIO T. TIONGSON, PETITIONER, VS. THE HONORABLE COURT OF APPEALS, TENTH DIVISION, HON. JUANITO M. CAGAMPAN, IN HIS CAPACITY AS PRESIDING JUDGE, REGIONAL TRIAL COURT, FIRST JU…

Tiongson versus Court of Appeals

The Case

This is a petition for review on certiorari brought by Antonio Tiongson against the Court of Appeals, its Tenth Division, and Judge Juanito Cagampan of the Regional Trial Court of Pangasinan. The petitioner asks the Supreme Court to modify a Court of Appeals decision that nullified the trial court's order dismissing certain agrarian cases for lack of jurisdiction. The case matters because it fixes, with precision, which body holds jurisdiction over agrarian disputes at a given moment, and it teaches the settled rule that jurisdiction is determined by the statute in force at the time the action is commenced.

Procedural History

The dispute began in the defunct Court of Agrarian Relations, which dismissed the complaints without prejudice and later rendered judgment on the counterclaims. That judgment was appealed to the Court of Appeals, which held that the private respondents could refile their complaints within a reasonable time. The private respondents then filed new cases before Branch 46 of the Regional Trial Court of Pangasinan. Acting on a motion to refer the matter to the Ministry of Agrarian Reform, the trial court, presided over by Judge Cagampan, issued an order dismissing the cases for lack of jurisdiction and advising the parties to file before the Ministry of Agrarian Reform.

The petitioner challenged that order in a petition for certiorari and mandamus before the Court of Appeals, which granted the petition, declared the trial court's order null and void, and directed the lower court to assume jurisdiction over the motion for liquidation, after which proceedings were to be suspended to allow the Ministry of Agrarian Reform to certify whether the cases were proper for trial. The petitioner then came to the Supreme Court by petition for review on certiorari under Rule 45.

Facts

In June 1972, twenty-seven complaints were filed against Antonio Tiongson before the Court of Agrarian Relations in Urdaneta, Pangasinan. The complainants sought a change from share tenancy to the leasehold system, the fixing of legal rentals, and damages, claiming to be tenants of Tiongson's landholding. Tiongson answered that the land was primarily devoted to sugarcane and that the complainants were mere seasonal or hired laborers.

After pre-trial, the private respondents failed to appear at scheduled hearings, prompting dismissal of the complaints without prejudice, while Tiongson was allowed to present evidence on his counterclaims. The Court of Agrarian Relations later rendered judgment awarding attorney's fees and making permanent an interlocutory order barring the private respondents from the landholding. On appeal, the Court of Appeals held that the private respondents could refile their complaints within a reasonable time.

In June 1978, the private respondents filed new cases before Branch 46 of the Regional Trial Court of Pangasinan for the change of share tenancy to leasehold and for the fixing of rentals. The trial court eventually dismissed the cases for lack of jurisdiction, advising the parties to file before the Ministry of Agrarian Reform. That dismissal led to the appellate proceedings and ultimately to this petition.

Issues

• Whether or not the Regional Trial Court had jurisdiction over the agrarian cases at the time they were commenced.
• Whether or not the transfer of agrarian jurisdiction to the Regional Trial Courts under the Judiciary Reorganization Act applied retroactively to cases already filed.
• Whether or not the Court of Appeals erred in ordering that the cases be referred to the Department of Agrarian Reform for certification.
• Whether or not the Court of Appeals erred in not issuing a preliminary mandatory injunction in favor of the petitioner.

Applicable Provisions

Section 17 of Executive Order No. 229 provides:

SEC. 17. Quasi-Judicial Powers of the DAR. -- The DAR is hereby vested with quasi-judicial powers to determine and adjudicate agrarian reform matters, and shall have exclusive original jurisdiction over all matters involving implementation of agrarian reform, except those falling under the exclusive original jurisdiction of the DENR and the Department of Agriculture (DA).

This provision divested the Regional Trial Courts of their general jurisdiction over agrarian cases and vested it in the Department of Agrarian Reform.

Section 50 of Republic Act No. 6657 provides:

SECTION 50. Quasi-Judicial Powers of the DAR. -- The DAR is hereby vested with primary jurisdiction to determine and adjudicate agrarian reform matters and shall have exclusive original jurisdiction over all matters involving the implementation of agrarian reform, except those falling under the exclusive jurisdiction of the Department of Agriculture (DA) and the Department of Environment and Natural Resources (DENR).

This provision substantially reiterates Section 17 of Executive Order No. 229 and confirms the exclusive original jurisdiction of the Department of Agrarian Reform.

Ruling

On the first issue, the Court held that at the time the complaints were filed, the Regional Trial Court had no jurisdiction, because Section 12 of Presidential Decree No. 946 then invested the Courts of Agrarian Relations with original exclusive jurisdiction over agrarian cases. Jurisdiction is determined by the statute in force at the time of the commencement of the action.

On the second issue, the Court ruled that the Judiciary Reorganization Act did not retroactively confer jurisdiction on the Regional Trial Court over cases filed years earlier. The Court held that such a defect is fatal, and that the grant of jurisdiction to the Regional Trial Courts over agrarian cases was not meant to have retroactive effect. The trial court therefore did not err in dismissing the cases.

On the third issue, the Court held that the Court of Appeals erred. By the time the challenged decision was promulgated, Section 17 of Executive Order No. 229 had divested the Regional Trial Courts of general jurisdiction over agrarian cases and vested it in the Department of Agrarian Reform, a holding confirmed by Section 50 of Republic Act No. 6657. The Court of Appeals therefore should not have directed the lower court to assume jurisdiction and merely suspend proceedings.

On the fourth issue, the Court did not grant the preliminary mandatory injunction, since the dismissal of the cases and their referral to the Department of Agrarian Reform disposed of the matter.

Doctrine

The jurisdiction of a court is determined by the statute in force at the time of the commencement of the action. A subsequent grant of jurisdiction to the Regional Trial Courts over agrarian cases under the Judiciary Reorganization Act does not apply retroactively to cases already filed when only the Courts of Agrarian Relations had jurisdiction. Under Section 17 of Executive Order No. 229 and Section 50 of Republic Act No. 6657, the Department of Agrarian Reform has exclusive original jurisdiction over all matters involving the implementation of agrarian reform, except those falling under the exclusive jurisdiction of the Department of Agriculture and the Department of Environment and Natural Resources. The special agrarian courts designated under Republic Act No. 6657 have exclusive original jurisdiction only over petitions for the determination of just compensation and the prosecution of criminal offenses under that Act.

Disposition

The Court reversed and set aside the decision of the Court of Appeals, reinstated the trial court's order of dismissal, and directed the trial court to forward the cases to the Department of Agrarian Reform for appropriate action as if they had been originally filed there.

Remember This

Memorize the rule that jurisdiction is fixed by the statute in force at the commencement of the action, and that agrarian jurisdiction now belongs to the Department of Agrarian Reform. Examiners use this case to test the non-retroactivity of jurisdictional statutes and the shift of agrarian jurisdiction from the Regional Trial Courts to the Department of Agrarian Reform.