G.R. No. 149764 ; November 22, 2006
PHILIPPINE OVERSEAS TELECOMMUNICATIONS CORPORATION, Petitioner, vs. ENRIQUE GUTIERREZ, ET AL., Respondents.

FACTS

Petitioner Philippine Overseas Telecommunications Corporation (POTC) filed a Complaint for Forcible Entry with the Municipal Circuit Trial Court (MCTC) against respondents. POTC alleged it was the lawful owner and possessor of a parcel of land in Pinugay, Rizal, covered by TCT No. 315142. It claimed that on August 5, 1993, respondents, organizing themselves into a cooperative, forcibly entered a portion of the land, destroyed crops, and built fences, thereby depriving POTC of possession. Respondents, in their answers, denied the material allegations and asserted they were tenant-farmers and actual occupants, with some claiming to have succeeded their parents as legitimate tenants of the former owners. They argued the land was covered by the Comprehensive Agrarian Reform Program (CARP) and that they were certified potential farmer-beneficiaries by the Department of Agrarian Reform (DAR). They contended the MCTC had no jurisdiction over the case, as it involved an agrarian dispute.
The MCTC dismissed the complaint for lack of jurisdiction, ruling that respondents and their predecessors had been in possession long before POTC acquired the property and that the action for forcible entry could not prosper as possession exceeded one year. Crucially, it held that since the land was subject to CARP and respondents were potential beneficiaries, the case constituted an agrarian dispute falling under the primary and exclusive jurisdiction of the DAR. The Regional Trial Court (RTC) and the Court of Appeals (CA) affirmed this dismissal.

ISSUE

Whether the MCTC correctly dismissed the forcible entry case for lack of jurisdiction on the ground that it involved an agrarian dispute under the primary jurisdiction of the DAR.

RULING

No. The Supreme Court reversed the decisions of the lower courts and reinstated the forcible entry case for trial on the merits. The Court held that the MCTC erred in dismissing the case for lack of jurisdiction. Jurisdiction over the subject matter in ejectment cases is determined by the allegations in the complaint. POTC’s complaint sufficiently alleged a cause of action for forcible entry under Rule 70 of the Rules of Court, claiming that respondents deprived it of possession by force, intimidation, and strategy within one year from the filing of the suit. These allegations, taken as true for jurisdictional purposes, vested the MCTC with jurisdiction.
The existence of an agrarian dispute does not automatically divest the MCTC of jurisdiction over an ejectment case. The Court clarified that the mere assertion by respondents of being tenants or potential CARP beneficiaries does not oust the MCTC of its jurisdiction. Such tenancy claims are matters of defense that must be proved during the trial. The MCTC should have first taken cognizance of the case to determine, based on evidence, whether a tenancy relationship truly exists. If proven, it could then refer the case to the DAR. By dismissing the case outright based solely on respondents’ unproven allegations, the MCTC abdicated its duty to resolve the preliminary issue of possession. The case was remanded to the MCTC to proceed with the trial.