Robles vs. Zambales Chromite Mining Company, et al.

An action for unlawful detainer under Section 1, Rule 72 of the Rules of Court may be brought in the proper inferior court over any land, including mineral land, because the rule’s reference to “any land” is unqualified and all kinds of land are covered.

Zambales Chromite Mining Company controlled certain mining properties and entered into a contract with Jose Robles under which possession of those properties was delivered to Robles, who was to extract, mine, and sell ores therefrom upon payment of certain royalties. The dispute implicated Section 1, Rule 72 of the Rules of Court, which authorizes an action for restitution of possession of “any land or building” unlawfully withheld after the expiration or termination of the right to hold possession by virtue of an express or implied contract.

Zambales Chromite Mining Company controlled certain mining properties. It entered into a contract with Jose Robles whereby the Company delivered possession of those mining properties to Robles. Under the contract, Robles was to extract, mine, and sell ores from the properties upon payment of certain royalties to the Company.

According to the Company, Robles violated the terms of the contract. The Company thereupon served notice on Robles to vacate the premises. Robles failed to comply with the demand.

On November 28, 1956, the Company filed a complaint for unlawful detainer against Robles in the Justice of the Peace Court of Sta. Cruz, Zambales, alleging the contract, Robles’s violation of its terms, the notice to vacate, and Robles’s failure to comply. The complaint thus sought to recover possession of the mining properties from Robles.

• Jurisdiction over Mineral Land: Petitioner maintained that the Justice of the Peace Court of Sta. Cruz, Zambales lacked jurisdiction over the unlawful detainer complaint because the case involved mineral land.

• Jurisdiction over Mineral Land: Whether the Justice of the Peace Court of Sta. Cruz, Zambales had jurisdiction over an action for unlawful detainer involving mineral land under Section 1, Rule 72 of the Rules of Court.

• Jurisdiction over Mineral Land: Yes. Section 1, Rule 72 of the Rules of Court authorizes an unlawful detainer action in the proper inferior court for the restitution of possession of “any land,” and that phrase includes all kinds of land, whether agricultural, residential, or mineral.

• Jurisdiction over Mineral Land: Section 1, Rule 72 provides that a landlord, vendor, vendee, or other person against whom possession of any land or building is unlawfully withheld after the expiration or termination of the right to hold possession by virtue of any contract, express or implied, may bring an action in the proper inferior court within one year for restitution, damages, and costs. The provision does not qualify the kind of land covered. Because “any land” is unqualified, it obviously includes all kinds of land, whether agricultural, residential, or mineral. The Court applied the maxim that where the law does not distinguish, courts should not distinguish. Accordingly, the Justice of the Peace Court had jurisdiction over the unlawful detainer complaint involving mineral land, and the Court of First Instance correctly ruled against Robles. The appeal was clearly without basis.

• Where the law does not distinguish, courts should not distinguish — When a statute or rule uses a general term without qualification, courts must not read into it distinctions not made by the lawmaking authority. The Court applied this maxim to Section 1, Rule 72, holding that its reference to “any land” includes mineral land and that the Justice of the Peace Court therefore had jurisdiction over the unlawful detainer case.
• Unlawful detainer jurisdiction over “any land” — Section 1, Rule 72 of the Rules of Court covers all kinds of land, whether agricultural, residential, or mineral. The Court thus affirmed that an inferior court may take cognizance of an unlawful detainer action involving mineral land.

• “a landlord, vendor, vendee, or other person against whom the possession of any land or building is unlawfully withheld after the expiration or termination of the right to hold possession, by virtue of any contract, express or implied, or the legal representatives or assigns of any such landlord, vendor, vendee, or other person, may, at any time within one year after such unlawful deprivation or withholding of possession, bring an action in the proper inferior court against the person or persons unlawfully withholding or depriving of possession, or any person or persons claiming under them, for the restitution of such possession, together with damages and costs.” — This is the Court’s quotation of Section 1, Rule 72, which defines the scope of unlawful detainer jurisdiction and supplies the phrase “any land” construed in the decision.
• “Any land spoken of in this provision obviously includes all kinds of land, whether agricultural, residential or mineral.” — This is the ratio decidendi: the unqualified phrase “any land” in Section 1, Rule 72 encompasses mineral land, thereby sustaining the Justice of the Peace Court’s jurisdiction.
• “It is a well known maxim in statutory construction that where the law does not distinguish, we should not distinguish.” — This is the canonical statutory-construction maxim on which the Court relied to reject the implied exclusion of mineral land from the rule’s coverage.

• Section 1, Rule 72, Rules of Court — Provides that a landlord, vendor, vendee, or other person against whom possession of any land or building is unlawfully withheld after the expiration or termination of the right to hold possession by virtue of any contract, express or implied, may bring an action in the proper inferior court within one year for restitution of possession, damages, and costs. The Court applied the provision by holding that its reference to “any land” includes mineral land, so the Justice of the Peace Court had jurisdiction over the unlawful detainer complaint.

Bengzon, Padilla, Montemayor, Reyes, A., Bautista Angelo, Labrador, Concepcion, Reyes, J.B.L., and Endencia, JJ.