Philippine Supreme Court Jurisprudence

LANDLORD AND TENANT; TENANCY LAW ENFORCEMENT DIVISION; JURISDICTION; LAND PLANTED TO ORANGE TREES. — The provisions of Commonwealth Act No. 461, as last amended by Republic Act No. 44, apply only to tenancies specially covered by tenancy statutes. The Tenancy Law Enforcement Division of the Department of Justice, an agency specified in said Act, charged with the duty of enforcing all the laws, orders and regulations relating to any system of tenancy, has no jurisdiction over tenancies involving lands dedicated or planted to orange trees, since there is no tenancy statute covering said lands.

Sabino Puyo, Luis Mercado and Joaquin Herrera filed with the Tenancy Law Enforcement Division of the Department of Justice a complaint dated March 16, 1950, against Tomas Villanueva, Maria Real y Lumanglas, Ramon Real, Jorge Cascalla and Crisanta Tolentino, alleging that since May, 1924, there has been a contract of tenancy between the plaintiffs and the defendants Tomas Villanueva, Maria Real y Lumanglas and Ramon Real, under which it was covenanted that the defendant Ramon Real would pay to the plaintiffs, in case the latter should leave their landholdings, one half of the amount of all the fruit-bearing orange trees they had planted at the price prevailing in the locality, plus two thirds of the fruits thereof; that on October 4, 1948, the defendant Maria Real y Lumanglas (daughter of defendant Ramon Real) sold the land held under tenancy, without the knowledge of the plaintiffs, to the defendants Jorge Cascalla and Crisanta Tolentino; that the latter took possession of the land, thereby ejecting the plaintiffs without paying the stipulated price of the orange trees and their share of the fruits thereof for the year 1950; that the defendants are bound to pay to the plaintiffs the sum of P2,750, as one half of the price of the orange trees planted by the plaintiffs, and the sum of P532, as the latter’s participation in the 1950 harvest, the payment of which by the defendants is prayed. The defendants filed a motion to dismiss, alleging that the Tenancy Law Enforcement Division has no jurisdiction, on the ground that the land in question is neither rice nor sugar land and, therefore, not within the purview of Commonwealth Act No. 461, as amended by Republic Act No. 44. The justice of the peace of Lobo, Batangas, as representative of the Tenancy Law Enforcement Division of the Department of Justice, denied the motion to dismiss as well as the subsequent motion for reconsideration filed by the defendants. Whereupon the defendants filed the present petition for prohibition against the Tenancy Law Enforcement Division, the justice of the peace of Lobo, Batangas, and the plaintiffs, in which we are asked to issue a restraining order.

In Felimon Arciga v. Hon. Ernesto de Jesus, * etc., Et Al., (47 Off. Gaz., 3463), was already held that the provisions of Commonwealth Act No. 461, as last amended by Republic Act No. 44, apply only to tenancies specially covered by tenancy statutes and that, there being no coconut tenancy law as yet, tenancy disputes involving coconut land did not fall under the jurisdiction of the Department of Justice and the Court of Industrial Relations. We reasoned out as follows:jgc:chanrobles.com.ph

"Commonwealth Act No. 461, as amended by Republic Act No. 44, provides that in all cases where land is held under any system of tenancy, the tenant shall not be dispossessed of the land cultivated by him except for any of the causes mentioned in section 19 of Act No. 4054, or for any just cause, and without the approval of a representative of the Department of Justice duly authorized for the purpose, and should the landowner or tenant feel aggrieved by the action taken by the Department of Justice, or in the event of any dispute between them arising out of their relationship as landowner and tenant, either party may appeal or resort to the Court of Industrial Relations which is given jurisdiction to determine the controversy in accordance with law. Said Act also provides that the Department of Justice is, likewise, charged with the duty of enforcing all the laws, orders and regulations relating to any system of tenancy.

"It is noteworthy that previous to the amendment introduced by Republic Act No. 44, the Department of Justice was ’charged with the duty of enforcing the Rice Share Tenancy Act’; whereas under Republic Act No. 44, this duty extends to the enforcement of ’all the laws, orders and regulations relating to any system of tenancy.’ In explaining the change under the latter Act, its sponsor (Congressman Roy) stated: ’The one special feature of those proposed amendments is to cover also the other Tenancy Act or the Sugar Tenancy Act (Act No. 4113, as amended). As it is now, no agency can enforce the rights of the parties in the Sugar Tenancy Act. Act No. 608 provides simply for the enforcement of the Rice Tenancy Act (Act No. 4054). This proposed measure will cover all and other tenancy acts which will be enacted.’

"This explanation gives way to the unmistakable legislative intent to apply the provisions of Commonwealth Act No. 461, as last amended by Republic Act No. 44, only to tenancies specially covered by tenancy laws. There have so far been enacted two tenancy statutes, namely, Rice Share Tenancy Act No. 4054, and Sugar Tenancy Act No. 4113. As the land here in question is admittedly coconut land, as to which no tenancy law has yet been promulgated, the dispute between the parties (even admitting the same to be one of tenancy as alleged by the petitioner) does not fall under the jurisdiction of the agencies specified in Commonwealth Act No. 461, as amended by Republic Act No. 44."cralaw virtua1aw library

As it is not pretended that there is a tenancy statute covering land dedicated or planted to orange trees, it necessarily follows that the respondent justice of the peace of Lobo, as representative of the Tenancy Law Enforcement Division of the Department of Justice, has no jurisdiction over the complaint filed by the respondents, Sabino Puyo, Luis Mercado and Joaquin Herrera. The decision in Ojo Et. Al., v. Jamito Et. Al., * (46 Off. Gaz., Supp., No. 11, p. 216), cited by the respondents, is not controlling, for the very obvious reason that said case arose from a single contract of tenancy covering both rice and coconut lands, and the jurisdiction of the Tenancy Law Enforcement Division had to be sustained because the dispute involved also rice land.

There is another ground for sustaining the present petition. It is to be noted that the complaint filed before the Tenancy Law Enforcement Division includes, as defendants, Jorge Cascalla and Crisanta Tolentino who were not parties to the alleged tenancy contract invoked by the individual respondents herein, with the result that there cannot be any tenancy dispute as to them.

Wherefore, the respondents Tenancy Law Enforcement Division and justice of the peace of Lobo, Batangas, are hereby enjoined from taking cognizance of and further proceeding with the complaint filed by the other respondents, Sabino Puyo, Luis Mercado and Joaquin Herrera. So ordered, without costs.

Feria, Pablo, Bengzon, Padilla, Tuason, Montemayor, Reyes, Jugo and Bautista Angelo, JJ., concur.

Endnotes:

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* 85 Phil., 348.

* 83 Phil., 764.