G.R. No. 150635, September 11, 2008
Dr. Rosalina G. Hilario, Petitioner, vs. Modesto Prudente, Crisanto Prudente and Remedios Prudente-Puno, Respondents.

FACTS

Petitioner Dr. Rosalina G. Hilario is the registered owner of a 10.2048-hectare agricultural land in Tanay, Rizal. A Notice of Coverage dated September 1, 1997 placed 5.2048 hectares of this land under the Comprehensive Agrarian Reform Program (CARP). Respondents, along with Benito Prudente, were identified as potential farmer-beneficiaries by the Municipal Agrarian Reform Office (MARO). Petitioner filed a protest with the Provincial Agrarian Reform Officer (PARO) against the inclusion of her land in CARP and the identification of the respondents as beneficiaries, claiming they were not tenants or occupant-tillers. The PARO denied her protest on February 3, 1998. Subsequently, on May 28, 1998, petitioner filed a forcible entry case with the Municipal Trial Court (MTC) against respondents, alleging they entered the land, cut trees, and built a house without her consent. The MTC ruled in favor of the petitioner, ordering respondents to vacate and pay rentals and attorney’s fees. On appeal, the Regional Trial Court (RTC) reversed the MTC, holding that an agrarian dispute existed and, pursuant to Section 50 of Republic Act No. 6657, jurisdiction belonged exclusively to the Department of Agrarian Reform (DAR). The Court of Appeals affirmed the RTC’s decision.

ISSUE

Whether the Municipal Trial Court had jurisdiction over the forcible entry case filed by the petitioner against the respondents, or whether jurisdiction properly lies with the Department of Agrarian Reform due to the existence of an agrarian dispute.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court held that the MTC did not have jurisdiction. The controversy constituted an agrarian dispute involving the implementation of CARP, over which the DAR has primary and exclusive original jurisdiction under Section 50 of R.A. No. 6657. The doctrine of primary jurisdiction precludes courts from resolving controversies initially lodged with an administrative body of special competence. The subject land was under CARP coverage, and the issue of respondents’ identification as farmer-beneficiaries was already raised and denied in the administrative protest. The filing of the ejectment case in the MTC was a legal maneuver to circumvent the unfavorable PARO ruling. The Court emphasized that a judgment in the forcible entry case would render the agrarian reform process inutile, as it would bar potential farmer-beneficiaries from possession of land they may own under CARP, thereby undermining the social justice objectives of the agrarian reform law.