On January 26, 1988, Leopoldo delos Reyes died. His daughter and sole heir, herein respondent Anita Flores, inherited the property. On June 28, 1991, Anita Flores and Jesus Fajardo executed an agreement, denominated as “KASUNDUAN NG PAGHAHATI NG LUPA AT PAGTATALAGA NG DAAN UKOL SA MAGKABILANG PANIG followed by another agreement, “KASUNDUAN SA HATIAN SA LUPA,” executed on July 10, 1991, wherein the parties agreed to deduct from Lot No. 2351 an area of 10,923 sq m, allotting the same to petitioner. Apparently, there was a conflict of claims in the interpretation of the Kasunduan between Anita Flores and Jesus Fajardo, which was referred to the DAR, Provincial Agrarian Reform Office, Baliuag, Bulacan. The case was referred to the Department of Agrarian Reform Adjudication Board (DARAB), Malolos, Bulacan.
On December 22, 2000, a complaint for ejectment was filed by herein respondent Anita Flores, assisted by her husband Bienvenido Flores, against petitioners with the Municipal Trial Court (MTC), San Ildefonso, Bulacan.
Petitioners filed a Motion to Dismiss, alleging that Lot No. 2351, was agricultural land; that they had been continuously, uninterruptedly, and personally cultivating the same since 1960 up to the present; that the MTC had no jurisdiction over the case, considering that the dispute between the parties, regarding the Kasunduan, was referred to the DARAB; and that the assumption by the DARAB of jurisdiction over the controversy involving the lot in question therefore precluded the MTC from exercising jurisdiction over the case.
Resolving the Motion to Dismiss, the MTC ruled that, while at first glance, the court did not have jurisdiction over the case, considering that it was admitted that petitioner was allowed to cultivate the land, a closer look at the Kasunduan, however, revealed that what was divided was only the portion being tilled. By contrast, the subject matter of the complaint was the stony portion where petitioners’ house was erected. Thus, the court ruled that it had jurisdiction over the subject matter. On April 25, 2001, the MTC rendered judgment in favor of respondent.
On appeal, the Regional Trial Court (RTC), Branch 16, Third Judicial Region, Malolos, Bulacan, affirmed the MTC Decision in toto upon a finding that no reversible error was committed by the court a quo in its Decision dated August 29, 2002. On motion for reconsideration, however, the RTC issued an Order on December 10, 2002, reversing its decision dated August 29, 2002. The RTC found that the issue involved appeared to be an agrarian dispute, which fell within the contemplation of Republic Act (R.A.) No. 6657, otherwise known as the Comprehensive Agrarian Reform Law of 1988, and thus ordered the dismissal of the case for lack of jurisdiction.
A petition for review was then filed by respondents with the CA to annul the Order of the RTC dated December 10, 2002. On October 28, 2004, the CA rendered the assailed decision, which reinstated the MTC decision. It disagreed with the findings of the RTC and ruled that the part of Lot No. 2351 where petitioners’ house stood was stony and residential in nature, one that may not be made to fall within the ambit of the operation of Philippine agrarian laws, owing to its non-agriculture character. The subsequent motion for reconsideration was denied; hence, this petition.
Issue: Whether it is MTC or the DARAB which has jurisdiction over the case.
Held: We agree with the RTC when it clearly pointed out in its Order dated December 10, 2002 that the resolution of this case hinges on the correct interpretation of the contracts executed by the parties. The issue of who has a better right of possession over the subject land cannot be determined without resolving first the matter as to whom the subject property was allotted. Thus, this is not simply a case for unlawful detainer, but one that is incapable of pecuniary estimation, definitely beyond the competence of the MTC.
An agrarian dispute refers to any controversy relating to tenurial arrangements, whether leasehold, tenancy, stewardship, or otherwise, over lands devoted to agriculture, including disputes concerning farmworkers’ associations or representation of persons in negotiating, fixing, maintaining, changing, or seeking to arrange terms or conditions of such tenurial arrangements. It includes any controversy relating to compensation of lands acquired under this Act and other terms and conditions of transfer of ownership from landowner to farmworkers, tenants, and other agrarian reform beneficiaries, whether the disputants stand in the proximate relation of farm operator and beneficiary, landowner and tenant, or lessor and lessee. It relates to any controversy relating to, inter alia, tenancy over lands devoted to agriculture.
Undeniably, the instant case involves a controversy regarding tenurial arrangements. The contention that the Kasunduans, which allegedly terminated the tenancy relationship between the parties and, therefore, removed the case from the ambit of R.A. No. 6657, is untenable. There still exists an agrarian dispute because the controversy involves the home lot of petitioners, an incident arising from the landlord-tenant relationship.
Furthermore, the records disclose that the dispute between the parties, regarding the interpretation of the Kasunduan, was, in fact, raised and referred to the DAR, which in turn referred the case to the DARAB. In view of the foregoing, we reiterate Hilario v. Prudente, that:
The doctrine of primary jurisdiction precludes the courts from resolving a controversy over which jurisdiction has initially been lodged with an administrative body of special competence. For agrarian reform cases, jurisdiction is vested in the Department of Agrarian Reform (DAR); more specifically, in the Department of Agrarian Reform Adjudication Board (DARAB).
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