Nonan v. Plan
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a writ of possession issued by a respondent judge against petitioners Pablo Nonan and Cristeta Alcantara, and a subsequent denial of their motion to set aside proceedings that could lead to contempt charges for non-compliance. The petitioners claim they are tenants and thus protected from ejectment under Presidential Decree No. 27. 2. Procedural History: Petitioners challenged the jurisdiction of the respondent judge in Special Civil Action No. 120 of the Court of First Instance of Isabela. The judge issued a writ of possession on January 15, 1973, acknowledging a pending case before the Court of Agrarian Relations. Petitioners subsequently filed a motion to set aside proceedings on August 3, 1973, citing their tenant status under Presidential Decree No. 27 and related issuances, which was denied on September 29, 1973. 3. The Petition: Petitioners seek a writ of certiorari, arguing that the respondent judge exceeded his jurisdiction by issuing the writ of possession and denying their motion. They contend that the judge failed to recognize the exclusive jurisdiction of agrarian courts over tenancy disputes and the protective provisions of Presidential Decree No. 27, which prohibits the ejectment of tenant farmers pending the promulgation of implementing rules.
Issue(s)
Whether the respondent Judge committed a grave abuse of discretion amounting to lack of jurisdiction in issuing a writ of possession and denying the motion to set aside proceedings in a case involving tenancy. Whether regular courts retain jurisdiction over tenancy controversies.
Ruling
The writ of certiorari is granted, and the orders of January 15, 1973, and September 29, 1973, are nullified and set aside. The respondent Judge is declared to be devoid of jurisdiction in Special Civil Action No. 120.
Ratio Decidendi
On the issue of jurisdiction over tenancy controversies: The Court reiterated the long-standing policy that regular courts have been relieved of and are shorn of power where suits involving tenancy are concerned. This policy, established as far back as 1939, has been consistently implemented by the Supreme Court through various decisions. The Court cited Ferrer v. Villamor, Ojo v. Juanito, and Salandanan v. Tizon to underscore this principle. Therefore, the respondent Judge, by entertaining a case that falls under the exclusive jurisdiction of the Court of Agrarian Relations, acted without jurisdiction. On the issuance of the writ of possession and denial of the motion to set aside: The respondent Judge's own admission that there was a pending case before the Court of Agrarian Relations should have cautioned him against issuing the writ of possession. Furthermore, the respondent Judge appeared to be oblivious to the legal effects of Presidential Decree No. 27 and related issuances, which prohibited the dispossession of tenant farmers pending the promulgation of implementing rules. The fact that the petitioners based their defense on these decrees, asserting their status as tenants who could not be ejected, should have been given due consideration. The challenged orders suffered from internal contradiction and a failure to observe jurisdictional limits in tenancy controversies, constituting a grave abuse of discretion.
Main Doctrine
Regular courts are divested of jurisdiction over tenancy controversies, and the issuance of a writ of possession by a regular court in a case involving tenancy is a grave abuse of discretion amounting to lack of jurisdiction.