GR L 1511; (May, 1949) (Digest)
G.R. No. L-1511; May 30, 1949
MIGUEL OJO, CECILIO OJO and ANGEL OJO, petitioners, vs. JOSE V. JAMITO as Justice of the peace of Vinzons, Camarines Norte, and CAYETANO VINZONS, respondents.
FACTS
Respondent Cayetano Vinzons filed an ejectment complaint before respondent Justice of the Peace Jose V. Jamito against petitioners Miguel, Cecilio, and Angel Ojo. The complaint alleged that the petitioners were “share-croppers” on Vinzons’ land and that their right to possess the land was terminated due to their failure to deliver 48 bocotes of palay in arrears since 1942. The petitioners, in their answer, denied the allegation of non-payment and asserted that the justice of the peace court lacked jurisdiction over the subject matter because the case involved a share tenancy relationship. They argued that under Commonwealth Act No. 461 , as amended, disputes involving the dispossession of a tenant fall under the exclusive jurisdiction of the Department of Justice (with appeal to the Court of Industrial Relations), not the regular courts.
ISSUE
Whether the respondent justice of the peace has jurisdiction over an ejectment case where the relationship between the parties is alleged to be that of landowner and share tenant.
RULING
No. The Supreme Court granted the petition for prohibition, holding that the justice of the peace court had no jurisdiction. Under Commonwealth Act No. 461 , as amended by Republic Act No. 44 , in all cases where land is held under any system of tenancy, a tenant cannot be dispossessed except for causes specified in the law and without the approval of a representative of the Department of Justice. Any grievance from the Department’s action may be appealed to the Court of Industrial Relations. This special law vested exclusive original jurisdiction over tenancy-related dispossession cases in the Department of Justice, thereby removing such matters from the general jurisdiction of courts of first instance and inferior courts like the justice of the peace. Since the complaint itself alleged a share-cropper (tenant) relationship, the justice of the peace was prohibited from taking cognizance of the case. The Court also noted that jurisdiction over the subject matter cannot be conferred by agreement or waiver of the parties.
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