G.R. No. 201631 , December 7, 2021
ANGELINA DAYRIT, REPRESENTED BY JULIE E. DAYRIT, PETITIONER, VS. JOSE I. NORQUILLAS, ET AL., RESPONDENTS.

FACTS

Petitioner Angelina Dayrit filed a complaint for forcible entry and/or unlawful detainer against the respondents before the Municipal Circuit Trial Court (MCTC) of Opol and El Salvador. In their Answer, the respondents alleged that the case involved an agrarian dispute and that the subject landholding was awarded to them as farmer beneficiaries under the Comprehensive Agrarian Reform Program (CARP). The MCTC proceeded with the case and eventually ruled in favor of the petitioner. The respondents appealed to the Regional Trial Court (RTC), which reversed the MCTC’s decision. The petitioner then filed a petition for review with the Court of Appeals (CA), which affirmed the RTC’s ruling. The petitioner elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the MCTC had jurisdiction over the complaint for forcible entry/unlawful detainer filed by the petitioner against the respondents.

RULING

The Supreme Court, through the ponencia, ruled that the MCTC had no jurisdiction over the complaint. Justice Perlas-Bernabe, in her Separate Concurring Opinion, concurred with this conclusion. She explained that while Batas Pambansa Bilang 129 generally grants Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts exclusive original jurisdiction over forcible entry and unlawful detainer cases, an exception exists when the complaint is actually a matter relative to the implementation of the agrarian reform program, constituting an agrarian dispute. In such cases, primary and exclusive jurisdiction lies with the Department of Agrarian Reform (DAR) under Section 50 of Republic Act No. 6657 (Comprehensive Agrarian Reform Law).
Justice Perlas-Bernabe noted that Republic Act No. 9700 , which amended RA 6657, reinforced the DAR’s exclusive jurisdiction by mandating the automatic referral of cases to the DAR upon an allegation from any party that the case is agrarian in nature and one of the parties is a farmer, farmworker, or tenant. This amendment, being procedural, applies retroactively to pending actions. In this case, the respondents’ Answer contained an allegation of an agrarian dispute and identified them as farmer beneficiaries. Therefore, under RA 9700, the case should have been automatically referred to the DAR to determine if an agrarian dispute exists.
However, Justice Perlas-Bernabe opined that based on the parties’ submissions, the case was clearly agrarian in nature and thus outside the MCTC’s jurisdiction. The subject properties were covered by the CARP, with portions already awarded to the respondents through Certificates of Land Ownership Award (CLOAs). The controversy over possession was inextricably linked to the implementation of CARP. Consequently, she concluded that the need for automatic referral could be dispensed with, and the MCTC should have dismissed the case for lack of jurisdiction. The DAR Adjudication Board (DARAB) is the proper forum to resolve the agrarian dispute.