GR 147570; (February, 2004) (Digest)
G.R. No. 147570 ; February 27, 2004
SPS. NUMERIANO and CARMELITA ROMERO, petitioners vs. MERCEDES L. TAN, FLORENTINA L. GONZALES, CELSO L. LUNA, MARIO LUNA and RAMON L. GARCIA, respondents.
FACTS
The petitioners, Spouses Romero, leased a fishpond in Lubao, Pampanga, from the respondents under a “Kasunduan Sa Pamuwisan” from 1996 to 1999, with an annual rent of P1.2 million. They claimed possession since 1985. In 1997, respondents filed an ejectment case before the Metropolitan Trial Court (MTC) of Malabon due to alleged unpaid rentals. The MTC rendered a judgment based on a compromise agreement where the petitioners, unrepresented by counsel, agreed to vacate by December 31, 1999. Before vacating, petitioners filed a complaint with the Provincial Agrarian Reform Adjudication Board (PARAB) to maintain peaceful possession, alleging a tenancy relationship. The PARAB ruled in their favor, declaring them tenants and nullifying a subsequent lease contract respondents executed with an intervenor.
ISSUE
The core issue is whether the PARAB had jurisdiction over the complaint, which hinges on whether a tenancy relationship existed over the fishpond.
RULING
The Supreme Court affirmed the Court of Appeals’ decision, ruling that the PARAB had no jurisdiction. The legal logic is anchored on the nature of the relationship and the property. For the PARAB to have jurisdiction, a tenancy relationship under agrarian laws must be established. The essential elements of agricultural tenancy include consent, personal cultivation, sharing of harvests, and the land being agricultural. The Court found these elements absent. The contract was a civil law lease for a fixed term and fixed monetary rental, not a tenancy agreement involving harvest sharing. Furthermore, the subject was a private fishpond. Under the law at the time ( R.A. No. 6657 , as amended by R.A. No. 7881 ), private lands actually, directly, and exclusively used for fishponds were exempt from Comprehensive Agrarian Reform Program (CARP) coverage. Consequently, the dispute fell outside agrarian reform laws. Jurisdiction properly pertained to regular courts. The MTC’s compromise judgment, which had become final, was thus valid. The PARAB’s assumption of jurisdiction was void.