G.R. No. 137350 ; June 19, 2000
Jaime P. Corpin, petitioner, vs. Amor S. Vivar and the Honorable Court of Appeals, respondents.

FACTS

Petitioner Jaime P. Corpin, the registered owner of a parcel of land in Bulacan, filed a complaint for ejectment against private respondent Amor S. Vivar before the Municipal Trial Court (MTC) of Guiguinto. Vivar, who was in possession of the land, refused to vacate, claiming he was a tenant of Corpin. In his Answer, albeit filed out of time, Vivar moved to dismiss the case for lack of jurisdiction, asserting that the dispute involved an agrarian landlord-tenant relationship falling under the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB). The MTC disregarded the Answer due to its late filing and, based solely on the complaint, rendered a decision ordering Vivar to vacate the land and pay rentals.
On appeal, the Regional Trial Court (RTC) reversed the MTC, dismissing the complaint for lack of jurisdiction. The RTC considered various documents submitted by Vivar for the first time on appeal, which purported to prove the tenancy relationship. Corpin then elevated the case to the Court of Appeals (CA), arguing that the RTC erred in considering evidence not presented before the MTC and in finding a tenancy relationship. The CA dismissed the petition, upholding the RTC’s actions and its finding on jurisdiction.

ISSUE

Whether the Court of Appeals erred in affirming the Regional Trial Court’s: (1) consideration of evidence not presented before the Municipal Trial Court; and (2) ruling that a landlord-tenant relationship exists, thereby stripping the MTC of jurisdiction over the ejectment case.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision, with modification. The Court held that the MTC committed a grave error in disregarding Vivar’s Answer simply because it was filed late. The Answer raised the fundamental issue of jurisdiction, which is a matter that may be considered at any stage of the proceedings and is not waived by procedural lapses. The MTC had the duty to resolve this jurisdictional question before proceeding with the merits.
On the propriety of the RTC considering new evidence on appeal, the Supreme Court ruled it was correct. Under Section 7, Rule 40 of the Revised Rules of Court, an RTC acting as an appellate court in an ejectment case may decide the appeal based on the entire record and such memoranda as are filed. The RTC was therefore authorized to examine the documents submitted by Vivar to determine the jurisdictional issue. The evidence, including certifications from agrarian reform and barangay officials, strongly indicated a tenancy relationship involving mango cultivation and sharing of harvest proceeds. Since the existence of a tenancy relationship places the case under the primary jurisdiction of the DARAB, the MTC had no jurisdiction over the ejectment complaint. The case was remanded to the MTC solely for a hearing to conclusively determine the issue of tenancy and jurisdiction.