Iburan vs. Labes

Act No. 4054, as made effective in Cebu by Proclamation No. 14, operates prospectively only and does not govern a pending unlawful detainer action already decided by the Justice of the Peace and pending on appeal when the proclamation issued; jurisdiction over remedies of the same nature arising from the same cause of action is indivisible.

Aniceta Iburan was the plaintiff-appellee and Magdaleno Labes the defendant-appellant in an unlawful detainer case over land in Carcar, Cebu, involving the tenant's undelivered share of products to the landowner. Act No. 4054, the Tenancy Law, approved on February 27, 1933, provided in section 29 that it would take effect only in provinces where a majority of the municipal councils petitioned the Governor-General, who would fix the effectivity date by proclamation. It was only on November 12, 1946, that Act No. 4054 as amended was declared in full force and effect in Cebu by Executive Proclamation No. 14. That statutory backdrop frames the dispute over whether the Tenancy Law applied to the already pending detainer case.

Aniceta Iburan, as plaintiff-appellee, commenced an action of unlawful detainer against Magdaleno Labes, defendant-appellant, in the Justice of the Peace Court of Carcar, Cebu. The dispute concerned the possession of land and the undelivered share of its products by the tenant to the owner. The Justice of the Peace Court decided against Labes. Labes appealed to the Court of First Instance of Cebu. In that court, Iburan reproduced her complaint and Labes filed his answer; execution of the Justice of the Peace judgment had been issued, although apparently it had not been carried out. By that stage, only the hearing and decision of the action in the Court of First Instance remained.

On November 12, 1946, while the case was pending in the Court of First Instance, Executive Proclamation No. 14 declared Act No. 4054, known as the Tenancy Law, as amended, in full force and effect in Cebu. Labes moved to dismiss on the ground that the allegations in the complaint brought the case within the provisions of the Tenancy Law. Judge Moscoso denied the motion to dismiss, stating that the case referred to the undelivered share of the products of the land in question by the tenants to the owner of the land, and that the Tenancy Act, made applicable to Cebu by Proclamation No. 14 dated November 12, 1946 only, did not cover the present action.

The Court of First Instance nevertheless rendered judgment for Iburan. It declared her right to the possession of the lands in question, ordered Labes to vacate and restore them to her, and ordered him to pay the products from 1945 to 1946 amounting to eight cavanes of palay with a total value of P200. The court declined to make any pronouncement as to the products for 1947 in view of the executive proclamation.

• Tenancy Law Coverage / Jurisdiction: Defendant-appellant, as the party appealing, contended that the allegations in the complaint brought the case within the provisions of Act No. 4054, known as the Tenancy Law, and its amendments, thereby challenging the Justice of the Peace Court's jurisdiction to take cognizance of the case as one of unlawful detainer.

• Jurisdiction of the Justice of the Peace Court / Applicability of Tenancy Law: Whether the Justice of the Peace Court had jurisdiction to take cognizance of the case as one of unlawful detainer, or whether the allegations in the complaint brought the case within the provisions of Act No. 4054, as amended.
• Indivisibility of Jurisdiction / Relief: Whether the lower court erred in granting part of the relief asked for and refusing to take jurisdiction over another part of the same cause of action.

• Jurisdiction of the Justice of the Peace Court / Applicability of Tenancy Law: Yes. The Justice of the Peace Court properly exercised jurisdiction as an unlawful detainer case; Act No. 4054 as made effective in Cebu by Proclamation No. 14 was prospective only and did not apply to the pending action.
• Indivisibility of Jurisdiction / Relief: The lower court erred in granting part of the relief and refusing to take jurisdiction over another part. Jurisdiction over remedies of the same nature arising from the same cause of action is indivisible. Because plaintiff did not appeal, the judgment could not be modified in her favor; her right to claim 1947 and subsequent rent or share was reserved in a separate action at law, not before the Department of Justice.

• Jurisdiction of the Justice of the Peace Court / Applicability of Tenancy Law: The ruling rested on the presumption that statutes are prospective unless the contrary clearly appears or is necessarily implied. Act No. 4054, Section 29, made effectivity contingent on municipal petitions and a gubernatorial proclamation fixing the date. Proclamation No. 14 declared the law in full force and effect "from and after" its date, which imports prospective operation. The presumption against retroactivity is stronger for pending actions, and no statute is construed to affect pending litigation unless the contrary appears. At the time of the proclamation, the case had already been decided by the Justice of the Peace, appealed to the Court of First Instance, and was awaiting hearing and decision; only the complaint and answer had been reproduced. The Tenancy Law therefore did not reach the pending case. Jurisdiction duly acquired under an existing statute is also not taken away by a subsequent statute prescribing a different method of commencing an action absent express prohibitory words.
• Indivisibility of Jurisdiction / Relief: Jurisdiction over remedies of the same nature arising from the same cause of action is indivisible, and courts should determine the entire controversy. Jurisdiction carries the power to hear and determine every issue properly arising and to grant full and complete relief. The lower court's judgment was self-contradictory: it awarded possession and the 1945-1946 products but refused to adjudicate the 1947 products, apparently contemplating recourse to a tenancy agency. If that agency could only fix the share, it could not determine the landlord's right to dismiss the tenant; if it could take all aspects, it would effectively annul the lower court's decision. The lower court thus erred in granting part of the relief and refusing jurisdiction over another part. Because plaintiff did not appeal, the Supreme Court could not modify the judgment in her favor; it reserved her right to claim 1947 and subsequent rent or share in a separate action at law, not before the Department of Justice.

• Prospective Operation of Statutes — Statutes are presumed to be prospective only in their operation rather than retrospective or retroactive, unless the contrary clearly appears, or is clearly, plainly, and unequivocally expressed or necessarily implied. A statute phrased to apply "hereafter," "thereafter," at a fixed future date, immediately, or "from and after" a designated date is prospective only. The Court applied this rule to Act No. 4054 and Proclamation No. 14, holding that the Tenancy Law did not govern the pending unlawful detainer case.
• Presumption Against Retroactivity in Pending Actions — The presumption against retroactivity is stronger with reference to pending actions or proceedings. No statute shall be so construed as to give it retroactive effect so as to affect pending litigation, and statutes which affect or change a remedy are presumed intended to exempt pending cases and proceedings from their operation unless the contrary appears. Because the case was already pending on appeal when Proclamation No. 14 issued, the Tenancy Law did not apply to it.
• Indivisibility of Jurisdiction Over Remedies — Jurisdiction over remedies of the same nature arising from the same cause of action is indivisible. It is the policy of the courts to determine the entire controversy between litigants, and jurisdiction carries with it the power to hear and determine every issue or question properly arising in the case and to grant full and complete relief. The lower court erred in granting part of the relief while refusing to take jurisdiction over another part of the same cause of action.
• Non-Impairment of Acquired Jurisdiction by Subsequent Statute — Where a court originally obtains and exercises jurisdiction, jurisdiction will not be overturned and impaired by any legislative enactment unless express prohibitory words are used. Jurisdiction duly acquired under an existing statute is not taken away by a subsequent statute prescribing a different method of commencing an action. This supported the conclusion that the Justice of the Peace Court's jurisdiction as an unlawful detainer case was not divested by the Tenancy Law.

• "Statutes are presumed to be prospective only in their operation rather than retrospective or retroactive, unless the contrary clearly appears, or is clearly, plainly, and unequivocally expressed or necessarily implied." — States the general rule of statutory construction applied to Act No. 4054 and Proclamation No. 14.
• "The presumption is stronger against retroactivity of a statute with reference to pending actions or proceedings. It has been generally held that "no statute shall be so construed as to give it retroactive effect so as to affect pending litigation."" — Explains why the Tenancy Law did not reach the case already pending on appeal when Proclamation No. 14 issued.
• "Proclamation No. 14 declared "The Philippine Rice Share Tenancy Act to be in full force and effect from and after the date of this proclamation throughout the Philippines." These words clearly import an intent to make the proclamation prospective." — Identifies the textual basis for holding that the proclamation did not apply retroactively to the pending case.
• "Jurisdiction over remedies of the same nature arising from the same cause of action is indivisible. It is the policy of the courts to determine the entire controversy between litigants." — States the rule that made the lower court's partial adjudication erroneous.

• Section 29, Act No. 4054 (Tenancy Law) — Provided that the Act shall take effect only in provinces where the majority of the municipal councils shall, by resolution, have petitioned for its application to the Governor-General, who thereupon shall, by proclamation, fix the date when the law shall take effect in said provinces. The Court relied on this contingent effectivity mechanism to conclude that the law's application was prospective.
• Act No. 4054, as amended (Tenancy Law) — The statute invoked by defendant-appellant; it was held not to apply to the pending unlawful detainer action because it was not yet effective in Cebu when the Justice of the Peace decided the case and because Proclamation No. 14 operated prospectively.
• Executive Proclamation No. 14 (November 12, 1946) — Declared the Philippine Rice Share Tenancy Act in full force and effect "from and after the date of this proclamation" throughout the Philippines. The Court construed these words as prospective, so the proclamation did not reach the pending case.

Moran, C.J., Ozaeta, Paras, Pablo, Bengzon, Montemayor, and Reyes, JJ., concur.