GR 169691; (July, 2008) (Digest)
G.R. No. 169691; July 23, 2008
Pedrito Salmorin, Petitioner, vs. Dr. Pedro Zaldivar, Respondent.
FACTS
Respondent Dr. Pedro Zaldivar, as legal possessor of an agricultural lot, designated petitioner Pedrito Salmorin as its administrator under a “Kasugtanan” (agreement) in 1989. Zaldivar later terminated Salmorin’s services for allegedly failing to till vacant areas of the property and filed an unlawful detainer complaint when Salmorin refused to vacate. In his answer, Salmorin claimed a tenancy relationship existed, thereby asserting that the Municipal Circuit Trial Court (MCTC) lacked jurisdiction, as agrarian disputes fall under the Department of Agrarian Reform Adjudication Board (DARAB).
The MCTC dismissed the case for lack of jurisdiction, finding it an agrarian dispute. On appeal, the Regional Trial Court (RTC) reversed, ruling no tenancy relationship existed due to the absence of essential elements like landowner consent and harvest sharing, and thus reinstated the ejectment case. The Court of Appeals affirmed the RTC’s decision, prompting Salmorin’s petition to the Supreme Court.
ISSUE
Whether the MCTC had jurisdiction over the unlawful detainer complaint, or whether the case was an agrarian dispute under the exclusive jurisdiction of the DARAB.
RULING
The Supreme Court denied the petition, affirming the CA and RTC. Jurisdiction over the subject matter is determined by the allegations in the complaint and the applicable law. Zaldivar’s complaint contained the essential allegations for unlawful detainer: his possession of the lot, Salmorin’s designation as administrator, termination for cause, a demand to vacate, and Salmorin’s unjustified refusal. This squarely fell within the exclusive original jurisdiction of the MCTC under BP 129, as amended.
The Court held that a defendant’s allegation of tenancy in an answer does not automatically divest an MCTC of jurisdiction. The court must receive evidence to determine if tenancy is the real issue. Here, both the RTC and CA correctly found that Salmorin failed to prove all indispensable elements of a tenancy relationship, particularly the consent of the landowner and an agreement to share the harvest. The absence of even one element negates tenancy. The certification from a Barangay Agrarian Reform Committee was deemed insufficient and not binding on the courts. Consequently, no agrarian dispute existed to oust the MCTC of its jurisdiction over the ejectment case. The case was remanded to the MCTC for expeditious proceedings.