Philippine Supreme Court Jurisprudence


Philippine Supreme Court Jurisprudence > Year 1954 > December 1954 Decisions > G.R. No. L-7373 December 22, 1954 - BENITO MENDOZA v. J. M. MANGUIAT

096 Phil 309:




PHILIPPINE SUPREME COURT DECISIONS

EN BANC

[G.R. No. L-7373. December 22, 1954.]

BENITO MENDOZA, Petitioner, v. J. M. MANGUIAT, Municipal Judge of the City of Lipa, Respondent.

Cefarino Inciong for Petitioner.

Municipal Judge J. M. Manguiat in his own behalf .


SYLLABUS


JURISDICTION; TENANCY CASE INVOLVING CITRUS LANDS; COURT OF INDUSTRIAL RELATIONS NOW HAS JURISDICTION. — In October 1953 justice of the peace and municipal courts still had jurisdiction to try tenancy cases involving lands planted with citrus trees. But, upon approval on August 30, 1954 of Republic Act No. 1199, which repeals Commonwealth Acts Nos. 454 and 461, the relation between the landowner and the tenant of citrus lands fell under the regulatory provisions of Republic Act No. 1199; as a consequence, the power of the municipal court to try and decide the case was revoked and transferred to the Court of Industrial Relations. The jurisdiction that was terminated is one over the subject-matter. A tenancy case involving citrus land field in October 1953 should, therefore, be dismissed and the plaintiff therein directed to file his action in the Court of Industrial Relations.


D E C I S I O N


LABRADOR, J.:


Action is brought in this Court to enjoin the Municipal Judge of Lipa City from taking cognizance of a case therein designated as "Tendency Case No. 3," and entitled "Francisco Macarandang v. Benito Mendoza." Said "tendency" case was filed on October 31, 1953. In his complaint Macarandang alleged that Benito Mendoza is cultivating a certain parcel of land belonging to Macarandang, which is planted to citrus. Mendoza did not like to take care of the citrus trees planted thereon by Macarandang, but he was to raise thereon diverse crops, like palay, corn and other short-lived crops. As a ground of action, it is alleged that inspite of the fact that Macarandang had given Mendoza notice that he (Macarandang) was to plant vines and other cover crops on the farm, Mendoza plowed half of it and, through carelessness, destroyed 56 citrus trees.

Mendoza, through counsel, moved to dismiss the action, on the ground that the Court of Industrial Relations has jurisdiction to hear and decide the said case and that he municipal court is without right to do so. The motion was denied on the authority of the decision of this Court in the case of Arciga v. De Jesus, 85 Phil., 348, 47 Off. Gaz. 3463. We held in said that (at the time) no tendency law had been promulgated governing the relations of the owner and the tenant of a coconut land. We have confirmed our ruling in that case in the recent case of Vidal v. Roldan, 92 Phil., 137, 48 Off. Gaz. (10) 4343.

But since then, and more specifically on August 30, 1954, Republic Act No 1199 entitled "An Act to Govern the Relations between Landholders and Tenants of Agricultural Lands (Leasehold and Share Tenancy)" has been approved. This law governs the relations between landlord and tenant in all kinds of agricultural lands. It repeals C. A. No. 454, known as the Rice Share Tenancy Act, and C. A. No. 461. The provisions of the Act are made to apply to all kinds of agricultural lands, whatever may be their nature or character, whether rice, sugar, corn or coconut, and all controversies between landlord and tenant are placed within the jurisdiction of the Court of Industrial Relations, so any controversies between landlord and tenant, or owner and lessee falls under said court’s jurisdiction.

So that at the time of the institution of the tenancy case in the municipal court of Lipa City on October 31, 1953, said court, therefore, still had jurisdiction to try the case, inasmuch as no law on tenancy had yet been passed governing citrus lands; the case was not yet cognizable by the Court of Industrial Relations, a court of special jurisdiction. But, upon approval of Republic Act No. 1199, the relation between the landowner and the tenant of the citrus land fell under the regulatory provisions of the Act; as a consequence, the power of the municipal court to try and decide the case was revoked and transferred to the Court of Industrial Relations. The jurisdiction that was terminated is one over the subject-matter (not like the power in a criminal case to try the case by virtue of the fact that the place where the offense committed was within the territorial limits of the court’s jurisdiction). The said case should, therefore, be, as it hereby is dismissed, and the plaintiff therein directed to file his action in the Court of Industrial Relations.

The petition for prohibition is hereby granted, without costs.

Paras, C.J., Pablo, Bengzon, Montemayor, Reyes, A., Jugo, Bautista Angelo, Concepcion, and Reyes, J. B. L., JJ., concur.




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