Facts:

The case at hand is Bibiana T. Vda. de Infante and Federico T. Infante vs. Ruperto Javier, Justice of the Peace Court of San Enrique, and Deogracias E. Lerma, Representative of the Tenancy Law Enforcement Division of the Department of Justice, G.R. No. L-2357, decided on September 28, 1949. The petitioners, Bibiana T. Vda. de Infante and Federico T. Infante, filed complaints for ejectment against their tenants, Lorenzo Fimeza and others, in the Justice of the Peace Court of San Enrique, Occidental Negros, under civil cases numbered 8 and 9. The court ruled in favor of the petitioners, ordering the tenants to vacate the premises. The tenants received the decision on May 20, 1947. However, prior to this ruling, on May 8, 1947, the tenants had filed complaints with the Tenancy Law Enforcement Division of the Department of Justice regarding the same property. Subsequently, on May 25, 1947, the parties entered into a stipulation agreeing to submit their dispute to the Tenancy Divi...

Facts:

Parties Involved:

• Petitioners-Appellees: Bibiana T. Vda. de Infante and Federico T. Infante (landlords).
• Respondents-Appellants: Ruperto Javier (Justice of the Peace of San Enrique) and Deogracias E. Lerma (Representative of the Tenancy Law Enforcement Division of the Department of Justice).
• Defendants in the original ejectment cases: Lorenzo Fimeza and companions (tenants).

Background:

• On April 17, 1947, the petitioners filed complaints for ejectment (civil cases Nos. 8 and 9) in the Justice of the Peace Court of San Enrique, Occidental Negros, against their tenants, Lorenzo Fimeza and companions.
• The tenants had returned to the farm after being previously driven away.
• After a hearing, the Justice of the Peace Court ruled in favor of the petitioners, ordering the tenants to vacate the premises.
• The tenants' attorney received the decision on May 20, 1947.

Tenancy Division Involvement:

• On May 8, 1947, the tenants filed complaints with the Tenancy Law Enforcement Division of the Department of Justice (Tenancy Division) against the petitioners, involving the same parties and properties.
• On May 25, 1947, the parties agreed in writing to submit their dispute to the Tenancy Division, stipulating that:
  • The tenants objected to the jurisdiction of the Justice of the Peace Court.
  • The parties agreed to abide by the Tenancy Division's decision.
  • The tenants agreed to respect the bond filed by the petitioners for temporary possession of the land pending the Tenancy Division's final decision.

Justice of the Peace Court's Declaration:

• On August 20, 1947, the Justice of the Peace of San Enrique declared that its actions in civil cases Nos. 8 and 9 were of no effect, citing Act No. 461 and related circulars.

Tenancy Division's Decision:

• On December 4, 1947, the Tenancy Division ruled in favor of the tenants and issued orders in their favor.

Petitioners' Motion for Execution:

• On December 20, 1947, the petitioners moved for execution of the ouster judgment in the Justice of the Peace Court.
• The motion was denied, leading to the filing of a special civil action for mandamus and injunction in the Court of First Instance of Occidental Negros.

Issue:

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Ruling:

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Ratio:

1. Jurisdiction of the Tenancy Division: The Supreme Court emphasized that under Commonwealth Act No. 461, as amended, disputes between landlords and tenants regarding possession or cultivation of land fall under the exclusive jurisdiction of the Tenancy Division of the Department of Justice. This is in line with the state's constitutional duty to regulate landlord-tenant relations.
2. Congressional Authority to Define Jurisdiction: The Court affirmed that Congress has the authority to define and apportion the jurisdiction of courts, including the power to transfer jurisdiction over specific matters (such as tenancy disputes) to administrative bodies like the Tenancy Division.
3. Invalidity of the Justice of the Peace Court's Decision: Since the Justice of the Peace Court lacked jurisdiction over the ejectment cases, its decision and any orders for execution were null and void.
4. No Interference with Tenancy Division's Authority: The Tenancy Division acted within its legal authority, and its decisions must be respected. The lower court's injunction against the Tenancy Division was therefore improper.

Conclusion:

The Supreme Court ruled that the Justice of the Peace Court had no jurisdiction over the ejectment cases, and the Tenancy Division's decision was valid and binding. The writ of mandamus and injunction issued by the lower court were reversed, and the Tenancy Division's authority was upheld.