Philippine Supreme Court Jurisprudence

Having obtained a judgment from the Court of Agrarian Relations (Bacolod City) against Claudio Hervias in the amount of P1,090.98 representing his share in sugar production plus P300.00 attorney’s fees, and having failed to secure its satisfaction by motion within five years from entry of judgment, Alejandro Depositario filed an action for the revival of said judgment with the City Court of Bacolod. The defendant moved for the dismissal of the case on the ground that the City Court had no jurisdiction over the same, which was a money claim arising from agrarian relations and therefore within the exclusive jurisdiction of the Court of Agrarian Relations. Sustaining the motion, the City Court dismissed the case.

Thereafter, the plaintiff filed the same revival case with the Court of Agrarian Relations at Bacolod City (CAR Case No. 2503). This time, defendant Hervias made a complete turn-about, contending that the Court had no jurisdiction over the case which was a pure money claim which arose, not from agrarian relations, but by virtue of a final judgment. The Court denied the motion and thereafter rendered judgment for the plaintiff, ordering the defendant to pay the amount of the revival judgment (1,390.98), P500.00 attorney’s fees and costs of suit. A motion for reconsideration was filed, but it was denied.chanrobles virtualawlibrary chanrobles.com:chanrobles.com.ph

Thence, an appeal was taken to the Court of Appeals which, in turn, certified the case to this Court as one involving solely a question of law.

Did the Court of Agrarian Relations err in ruling that it had jurisdiction over the case and rendering judgment thereon? Appellant maintains that since the action was for revival of judgment, the same is a new and original action, i.e., a pure money claim not arising from agrarian relations and therefore outside the jurisdiction of the Courts of Agrarian Relations.

Appellant’s duplicity deserves the outright rejection of his claim. A party will not be allowed to make a mockery of justice by taking inconsistent positions which, if allowed, would result in brazen deception. The doctrine of estoppel bars a party from trifling with the courts and flaunting the elementary rules of right dealing and good faith. (Crisostomo Et. Al. v. Court of Appeals Et. Al., 32 SCRA 54; People v. Acierto, 92 Phil. 534.).chanrobles.com : virtual law library

At any rate, when the court a quo took cognizance of CAR Case No. 2503, the prevailing legislative policy was to confine agrarian cases as well as their incidents within the exclusive jurisdiction of the Courts of Agrarian Relations. Thus, the Agrarian Land Reform Code sweepingly gave the Courts of Agrarian Relations original and exclusive jurisdiction over "all cases and actions involving matters, controversies, disputes or money claims arising from agrarian relations" and endowed the said courts with all the powers and prerogatives inherent in or belonging to the Courts of First Instance. (Republic Act 3844, Sections 154-155.) Therefore, following the ruling in Babula Vda. de Luding v. Borromeo (100 SCRA 432), the said Courts had exclusive jurisdiction over actions to revive and enforce their own final judgments.

The judgment under review was promulgated way back in 1974. It is high time that the just claim of the appellee, which is but a modest amount, be satisfied without further delay.

WHEREFORE, upon the finality of this decision, the Clerk of Court of this Division is directed to immediately issue a writ of execution directly to the Sheriff, c/o the Clerk of Court, Regional Trial Court, at Bacolod City for the satisfaction of the judgment in CAR Case No. 2503. Costs against the Appellant.

SO ORDERED.

Teehankee (Chairman), Melencio-Herrera, Vasquez, Relova and Gutierrez, Jr., JJ., concur.