G.R. No. 152564 ; September 13, 2004
Eugenio Bautista, Romeo Cruz and Carmencita B. Cruz, petitioners, vs. Susana Mag-Isa Vda. De Villena, respondent.

FACTS

The subject property is an agricultural lot in San Rafael, Bulacan. The late Aquilino Villena, husband of respondent Susana Mag-Isa Villena, was the original tenant-tiller of the land, then owned by Maria Lopez Caluag, beginning in 1946. The tenancy relationship continued with Susana after Aquilino’s death. In 1957, upon Caluag’s instruction, Susana’s house was transferred to a 1,000-square-meter portion of the lot, which was given to her as a home lot and seedbed. Susana remained in peaceful possession until 1987, when petitioners Eugenio Bautista, Romeo Cruz, and Carmencita Cruz, who subsequently acquired the property, filed an ejectment case against her. That case did not prosper.
Petitioners subsequently filed an action for quieting of title and recovery of possession before the Regional Trial Court (RTC) of Bulacan in 1990. The RTC ruled in favor of the petitioners. On appeal, the Court of Appeals reversed the RTC, dismissing the complaint. The CA held that the case involved an agrarian dispute over a home lot, falling within the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB), not the regular courts.

ISSUE

Whether the case, involving the right to possess and occupy a home lot granted to an agricultural lessee, falls under the exclusive jurisdiction of the DARAB.

RULING

Yes, the DARAB has exclusive jurisdiction. The Supreme Court affirmed the Court of Appeals’ dismissal of the complaint for lack of jurisdiction on the part of the RTC. The core legal principle is the doctrine of primary jurisdiction, which precludes courts from resolving controversies initially lodged with an administrative body of special competence. For agrarian reform matters, this jurisdiction is vested in the DAR, specifically the DARAB.
The dispute is quintessentially an agrarian dispute. An agrarian dispute includes any controversy relating to tenurial arrangements over lands devoted to agriculture. The right to a home lot is intimately connected to the tenancy relationship, granted by agrarian laws for the lessee’s dwelling and subsistence. The controversy here—whether respondent, as a surviving spouse and successor-in-interest of the original tenant, retains the right to possess and occupy the home lot against the new landowners—directly relates to the terms and conditions of her tenurial arrangement. Since the case involves the implementation of agrarian laws concerning a tenant’s home lot, it falls squarely within the DARAB’s primary and exclusive original jurisdiction under Republic Act No. 6657 (Comprehensive Agrarian Reform Law) and related issuances. Consequently, the RTC had no jurisdiction to entertain the action for quieting of title and recovery of possession.