G.R. No. 149765 . April 12, 2005.
ARTURO MEJIA, Petitioner, vs. FILOMENA GABAYAN, ALBIN RUEME, ERNESTO MEJIA, CARLOS RAMOS, JOSEFINA LACADIN and PEDRO GAVINO, Respondents.

FACTS

Petitioner Arturo Mejia is the registered owner of a 10.4-hectare parcel of land in Isabela, originally part of a homestead patent granted to his father. In 1978, the Department of Agrarian Reform (DAR) issued Certificates of Land Transfer (CLTs) over portions of this land to several farmer-beneficiaries, the respondents. Mejia sought the cancellation of these CLTs and filed a petition with the DAR for the property’s exclusion from the coverage of Presidential Decree No. 27. While this administrative petition was pending, Mejia, citing the Supreme Court ruling in Alita v. Court of Appeals which held that homestead lands are exempt from P.D. No. 27, filed a complaint for declaratory relief and recovery of possession with the Regional Trial Court (RTC) of Isabela. The RTC granted summary judgment in favor of Mejia, declaring his better right to possession and ordering the respondents to vacate.

ISSUE

The core issue is whether the Regional Trial Court had jurisdiction over Mejia’s action for declaratory relief and recovery of possession, or if jurisdiction over the agrarian dispute lies exclusively with the Department of Agrarian Reform Adjudication Board (DARAB).

RULING

The Supreme Court ruled that the RTC had no jurisdiction; jurisdiction was vested in the DARAB. The Court clarified that the pivotal question was not the applicability of P.D. No. 27 to homestead lands—a substantive issue—but the nature of the dispute for determining proper jurisdiction. The complaint alleged an agrarian relationship, as Mejia himself identified the respondents as his agricultural tenants. This characterization placed the controversy squarely within the definition of an agrarian dispute under Republic Act No. 6657 , which encompasses any controversy relating to tenurial arrangements over agricultural lands. The law explicitly confers original and exclusive jurisdiction over such disputes upon the DARAB. Consequently, the RTC’s decision was null and void for lack of jurisdiction. The Court emphasized that jurisdiction is conferred by law and cannot be vested by the parties’ agreement or waived. The existence of a tenancy relationship, alleged in the pleadings, was sufficient to divest the RTC of jurisdiction, regardless of the eventual merit of the claim under the Alita doctrine.