G.R. No. 149765. April 12, 2005.
ARTURO MEJIA, Petitioner, vs. FILOMENA GABAYAN, ALBIN RUEME, ERNESTO MEJIA, CARLOS RAMOS, JOSEFINA LACADIN and PEDRO GAVINO, Respondents.

FACTS

Petitioner Arturo Mejia is the registered owner of a 10.4-hectare land in Isabela, originally part of a homestead patent granted to his father. In 1978, the Department of Agrarian Reform (DAR) issued Certificates of Land Transfer (CLTs) over portions of this land to several farmer-beneficiaries, the respondents herein. Mejia sought the cancellation of these CLTs with the DAR. Relying on the Supreme Court ruling in Alita v. Court of Appeals, which held that homestead lands are exempt from Presidential Decree No. 27, Mejia filed a complaint for declaratory relief and recovery of possession before the Regional Trial Court (RTC) in 1994. He argued the land was not covered by agrarian reform and demanded the respondents vacate.
The respondents contended the RTC lacked jurisdiction, asserting the dispute was agrarian in nature and thus within the exclusive original jurisdiction of the DAR Adjudication Board (DARAB). They highlighted the pending DAR administrative case filed by Mejia himself concerning the same property. The RTC rendered a summary judgment in favor of Mejia, ordering the respondents to vacate, based on the Alita doctrine. The respondents appealed to the Court of Appeals.

ISSUE

Whether the Regional Trial Court had jurisdiction over Mejia’s action for declaratory relief and recovery of possession, or whether jurisdiction properly pertained to the Department of Agrarian Reform and its adjudicatory bodies.

RULING

The Supreme Court denied Mejia’s petition, affirming the Court of Appeals’ decision that the RTC lacked jurisdiction. The Court clarified that while the Alita doctrine correctly exempts homestead lands from the compulsory coverage of P.D. No. 27, it does not automatically strip the DAR of jurisdiction over related tenancy disputes. The core issue in Mejia’s complaint involved the rights of the respondents as alleged tenants and beneficiaries under agrarian laws, including their security of tenure and the validity of the CLTs issued to them.
These matters—specifically, the determination of tenancy relationships, the issuance and cancellation of CLTs, and the rights of farmer-beneficiaries—fall squarely within the exclusive original jurisdiction of the DARAB as provided by law and executive issuance. The existence of a tenancy relationship, which the respondents claimed and which was evidenced by the issued CLTs, places the controversy under agrarian reform laws. Consequently, the RTC had no authority to adjudicate the case. The proper recourse for Mejia was to pursue and exhaust the administrative remedies within the DAR system. The RTC’s judgment was therefore declared null and void for lack of jurisdiction.