GR 170478; (May, 2008) (Digest)
G.R. No. 170478 ; May 22, 2008
SPS. TERESITO Y. VILLACASTIN and LOURDES FUA VILLACASTIN, petitioners, vs. PAUL PELAEZ, respondent.
FACTS
Petitioners Spouses Villacastin filed a Complaint for Forcible Entry with the Municipal Circuit Trial Court (MCTC) against respondent Paul Pelaez. They alleged they were the owners and actual possessors of an agricultural landholding, having purchased it at a foreclosure auction after it was mortgaged by Pelaez to the Development Bank of the Philippines. They claimed Pelaez unlawfully deprived them of possession. Pelaez countered that he had redeemed the property and reacquired possession, and asserted that the land was tenanted.
Simultaneously, the purported tenant-farmers of the same land had earlier filed a case before the Department of Agrarian Reform Adjudication Board (DARAB) seeking annulment of the mortgage, foreclosure, and sale. The DARAB eventually declared the tenants as bona fide farmers under P.D. No. 27 and nullified the mortgage and subsequent sale to the Villacastins. The MCTC, however, ruled in favor of the Villacastins in the forcible entry case, a decision affirmed by the Regional Trial Court (RTC).
ISSUE
Whether the MCTC had jurisdiction over the forcible entry case, or if primary and exclusive jurisdiction belonged to the DARAB because the case involved an agrarian dispute over an agricultural land.
RULING
The Supreme Court ruled that the MCTC validly exercised jurisdiction. The complaint was a simple action for forcible entry, concerned solely with the issue of physical or material possession (possession de facto). It did not raise any agrarian dispute requiring the expertise of the DARAB. An agrarian dispute, over which the DARAB has exclusive original jurisdiction, involves controversies relating to tenurial arrangements, compensation, or terms of transfer under agrarian laws.
The Court distinguished between possessory actions and agrarian disputes. The determination of who has the better right of physical possession is independent from questions regarding tenurial rights, land ownership, or the validity of agrarian transfers. Regular courts retain jurisdiction over ejectment cases to resolve the issue of possession, even if the property is agricultural. The DARAB’s nullification of the sale did not automatically divest the MCTC of jurisdiction to adjudicate the purely possessory issue raised in the forcible entry complaint. Therefore, the Court of Appeals erred in dismissing the case for lack of jurisdiction. The decisions of the MCTC and RTC were reinstated.