GR 128392; (April, 2005) (Digest)
G.R. No. 128392; April 29, 2005
CESAR MATEO, ET AL., Petitioners, vs. COURT OF APPEALS AND CASIMIRO DEVELOPMENT CORPORATION, Respondents.
FACTS
Private respondent Casimiro Development Corporation (CDC) filed an unlawful detainer complaint against petitioners before the Metropolitan Trial Court (MeTC) of Las Piñas. CDC alleged it acquired the subject land from China Banking Corporation and demanded petitioners, who were occupying it, to pay rentals and vacate. The MeTC ruled for CDC, ordering petitioners to vacate and pay compensation.
Petitioners elevated the case to the Regional Trial Court (RTC) via a petition for certiorari and prohibition. They contended the MeTC lacked jurisdiction, arguing the land was agricultural and the dispute agrarian, falling under the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB). The RTC reversed the MeTC, agreeing that the land, classified as a fishpond, was agricultural under the Comprehensive Agrarian Reform Law (CARL), thus DARAB had jurisdiction.
ISSUE
Whether the MeTC had jurisdiction over the unlawful detainer case or if jurisdiction properly pertained to the DARAB as an agrarian dispute.
RULING
The Supreme Court ruled that the MeTC had jurisdiction. For a case to be considered an agrarian dispute under DARAB’s exclusive jurisdiction, a tenancy relationship must be proven. The essential elements are: (1) the parties are the landowner and the tenant; (2) the subject is agricultural land; (3) there is consent; (4) the purpose is agricultural production; (5) there is personal cultivation by the tenant; and (6) there is sharing of harvests.
The Court found petitioners failed to establish a tenancy relationship. They did not prove consent from either CDC or their alleged predecessor-in-interest to work the land. There was also no evidence of any sharing arrangement of harvests. The mere classification of the land as agricultural in a tax declaration is insufficient to confer jurisdiction on the DARAB absent proof of tenancy. Since no tenancy relationship was shown, the dispute remained a simple ejectment case over which the MeTC properly exercised jurisdiction. The Court of Appeals decision affirming the MeTC’s jurisdiction was upheld.