GR 142501; (December, 2001) (Digest)
G.R. No. 142501; December 7, 2001
LEONARDA L. MONSANTO, petitioner, vs. JESUS AND TERESITA ZERNA AND COURT OF APPEALS, respondents.
FACTS
Spouses Jesus and Teresita Zerna were charged with qualified theft before the Regional Trial Court (RTC) for harvesting coconuts from a plantation owned by Leonarda Monsanto and converting them into copra. The RTC acquitted the spouses, finding no criminal intent to gain, as they acted to confirm their claim of being agricultural tenants. The court, however, ordered the delivery of the copra sale proceeds deposited with the barangay to Monsanto. Subsequently, upon Monsanto’s motion, the RTC further ordered the spouses to pay her an additional P1,100, which they had retained as compensation for their labor, ruling they were not entitled to it as their acts were done without her consent.
ISSUE
Whether the Regional Trial Court, in a criminal case for qualified theft, had jurisdiction to adjudicate the civil liability for the retained P1,100, given the claim of an agricultural tenancy relationship between the parties.
RULING
The Supreme Court ruled that the RTC had no jurisdiction. While the filing of a criminal action carries the civil liability arising from the offense, a court cannot adjudicate civil matters beyond its competence. The core dispute—whether the Zernas were entitled to compensation for harvesting and processing coconuts—is intrinsically linked to the issue of tenancy. The defense of tenancy was raised, and the acts complained of (harvesting, processing, sale) were interwoven with the alleged agrarian relationship. Jurisdiction over such agrarian disputes is vested by law primarily and exclusively in the Department of Agrarian Reform Adjudication Board (DARAB). Consequently, the RTC, in the criminal case, exceeded its jurisdiction by ruling on the civil aspect pertaining to the tenancy claim. Its orders regarding the P1,100 were null and void. The parties must refer their dispute to the proper agrarian authorities. The Petition was denied and the Court of Appeals’ decision was affirmed.