Case Summary (G.R. No. L-15264)
Relevant Transactions and Agreements
Garcia Samson alleges that in 1913, he entered into a tenancy agreement (contrato de aparceria) with Jose Borja, who acted as the attorney-in-fact for the co-owners of the land. Samson asserts that under this agreement, he was entitled to cultivate the land in exchange for annual payments of 25 cavanes of palay to the owners. He maintains that he possessed the land peacefully from 1913 until his dispossession on April 13, 1955, when the defendants forcibly entered and destroyed his planted bamboo groves and continued to prevent him from recovering possession.
Defendants' Response and Counterarguments
In their response filed on July 14, 1955, the defendants denied the plaintiff's claims and raised several key defenses. They contended that Samson had no written contract establishing his rights over the land and argued that he was merely a cropper with temporary rights limited to the agricultural cycle, which expired annually. The defendants also alleged that the tenancy agreement was terminated with the death of Jose Borja and that they had legally engaged someone else to work the land.
Procedural Developments
Following the filing of the complaint, the Municipal Court of Zamboanga City issued a preliminary injunction to maintain the status quo while the case was pending. However, on October 25, 1955, the defendants filed a motion to dismiss, asserting lack of jurisdiction and failure to state a cause of action, stating that the case involved tenancy matters that fell under the exclusive jurisdiction of the Court of Agrarian Relations as per Republic Act No. 1267.
Municipal Court's Ruling
On May 12, 1956, the Municipal Court recognized the existence of a tenancy relationship between Samson and the defendants and acknowledged that the matter involved a system of cultivation, compelling it to decline jurisdiction. Consequently, the case was sent to the Court of Agrarian Relations for appropriate handling.
Actions by the Court of First Instance and Subsequently
The case persisted through various appeals. A procedural decision by the Court of First Instance of Zamboanga on November 9, 1957, essentially reversed the lower court's transfer, reasserting jurisdiction over the forcible entry claim. However, on March 20, 1958, the Municipal Court eventually ruled in favor of Samson, reclaiming his possession of Lot No. 422 and awarding damages and attorney's fees.
Appeal to Higher Courts and Final Decision
The defendants appealed the Municipal Court's ruling to the Court of First Instance, which again contended that the case was improperly under the jurisdiction of the regular courts and should be handled by the Court of Agrarian Relations. The first instance reaffirmed t
...continue readingCase Syllabus (G.R. No. L-15264)
Case Background
- On June 24, 1955, Garcia Samson filed a verified complaint in the Municipal Court of Zamboanga City against Ramon Enriquez and Fermin Filoteo.
- The complaint sought recovery of possession of Lot No. 422, located in Zamboanga City, along with P1,150 for actual and moral damages, P250 for attorney's fees, and additional just relief.
- Alongside the complaint, Samson applied for a writ of preliminary injunction to prevent the defendants from disturbing his possession of the land, which he was cultivating with palay (rice).
Plaintiff's Allegations
- Samson claimed that in 1913, he and the deceased Jose Borja entered into a tenancy contract (contrato de aparceria) allowing him to cultivate the land in exchange for 25 cavanes of palay annually to the landowners.
- He asserted that he had been in peaceful possession of the land from 1913 until April 13, 1955.
- On the stated date, the defendants allegedly used force and intimidation to dispossess him from the land.
- The defendants were accused of cutting down bamboo groves he had planted, resulting in damages of P150, and of refusing to restore possession, causing further damages of P1,000.
- Samson argued that he had to engage legal counsel due to the defendants' actions, incurring P250 in fees.
Defendants' Response and Counterclaims
- The defendants denied the allegations, claiming that Samson lacked a written contract with the landowners and had never held lawful possession of the land.
- They contended