G.R. No. 109992 ; March 7, 2000
HEIRS OF THE LATE HERMAN REY SANTOS, represented by his widow ARSENIA GARCIA VDA. DE SANTOS, petitioners, vs. THE COURT OF APPEALS, HON. JOSE REYES, in his capacity as Provincial Agrarian Reform Adjudicator (PARAD) of Malolos, Bulacan, HON. ERASMO CRUZ, in his capacity as former Provincial Agrarian Reform Adjudicator (PARAD) Malolos, Bulacan, DARAB SHERIFF AMANDO C. DIONISIO, EXEQUIEL GARCIA and/or ADELA GARCIA and PANTALEON ANTONIO, respondents.

FACTS

The controversy involves a parcel of land in Bulacan levied on execution and sold at public auction, with Herman Rey Santos (now represented by his heirs) as the winning bidder. After the redemption period lapsed, a final deed of sale was executed and registered in Santos’s favor. Subsequently, the former owner, Exequiel Garcia, filed a Petition for Injunction and Damages with the Department of Agrarian Reform Adjudication Board (DARAB) to prevent Santos from harvesting mango fruits, leading the Provincial Adjudicator to issue an order allowing the harvest and directing the proceeds be deposited with the Board.
During the DARAB proceedings, Pantaleon Antonio filed a motion to intervene, claiming a right to the harvest as the one who tended the mango trees. The DARAB, while suspending hearings on the main case due to a pending ownership dispute before the Regional Trial Court (RTC), proceeded to grant Antonio’s motion to withdraw half of the harvest proceeds and recognized him as an agricultural tenant. The Court of Appeals affirmed the DARAB’s orders.

ISSUE

Whether the DARAB had jurisdiction over the ancillary matter of intervention and the harvest proceeds, given the pending issue of ownership before the RTC and the absence of a tenancy relationship between the original contending parties.

RULING

The Supreme Court ruled that the DARAB had no jurisdiction. Jurisdiction of the DARAB is limited by law to agrarian disputes, which require, as a condition precedent, a tenurial relationship between the parties, such as that of landowner and tenant or agricultural lessee. The Court, citing Morta v. Occidental, emphasized that all indispensable elements of tenancy must be established for the DARAB to take cognizance.
In this case, the core controversy was between Santos and Garcia, who were adverse claimants to the ownership of the land itself. No tenurial, leasehold, or agrarian relation existed between them. The DARAB itself recognized in its April 3, 1992 order that the fundamental issue was one of ownership. Consequently, the DARAB should not have entertained Garcia’s petition for injunction in the first place.
Since the DARAB lacked jurisdiction over the main case, it necessarily lacked jurisdiction over the ancillary motion for intervention filed by Pantaleon Antonio. The issue of who had the right to harvest the fruits was incidental and dependent on the resolution of the ownership dispute, which was properly within the jurisdiction of the RTC where an action was already pending. The Supreme Court granted the petition, reversed the Court of Appeals, set aside the DARAB orders, and directed the DARAB to transfer the deposited funds to the RTC. Antonio was ordered to redeposit the amount he had withdrawn.