G.R. No. 152027 ; September 27, 2006
ERNESTO DELA CRUZ, petitioner, vs. SPOUSES NESTOR F. MENDOZA and MARCELINA G. MENDOZA, respondents.

FACTS

Respondent spouses purchased a parcel of land previously mortgaged and later owned by the Spouses Tetangco. Upon taking possession, they built a fence and placed a “no trespassing” sign. Petitioner Ernesto Dela Cruz, claiming to be an agricultural tenant who succeeded the original tenant, Bonifacio San Luis, entered the land, removed the sign, and prevented respondents from entering. Respondents filed a forcible entry case (Civil Case No. 1039) before the Municipal Trial Court (MTC), which ruled in their favor, a decision affirmed by the Regional Trial Court and the Court of Appeals (CA). The CA held the land was an orchard, not tenanted riceland, thus the MTC had jurisdiction.
Simultaneously, petitioner filed a tenancy case before the Department of Agrarian Reform Adjudication Board (DARAB). The Provincial Adjudicator initially dismissed it, but the DARAB Central Office later reversed this, declaring petitioner a lawful tenant. Respondents challenged this DARAB decision in a separate petition (CA-G.R. SP No. 81238) pending before the CA.

ISSUE

Whether the Court of Appeals erred in affirming the lower courts’ jurisdiction over the forcible entry case despite a pending resolution on the tenancy relationship between the parties.

RULING

The Supreme Court granted the petition and set aside the CA’s decision. The legal logic centers on the doctrine of litis pendentia and the jurisdictional primacy of the DARAB over tenancy issues. The Court found that the forcible entry case could not be resolved independently from the pending tenancy case (CA-G.R. SP No. 81238). The core issue in both proceedings was possession, which in the agrarian context depended on the existence of a tenancy relationship—a matter within the DARAB’s exclusive original jurisdiction.
The Court reasoned that if the CA in the tenancy case ultimately sustains the DARAB’s finding that petitioner is a tenant, jurisdiction over the possessory dispute would be removed from the MTC. Allowing both actions to proceed simultaneously risked conflicting judgments on the same fundamental issue of possession. Citing Spouses Tirona v. Hon. Alejo, the Court emphasized that to avoid vexing a party twice over the same subject and to ensure stability of rights, the resolution of the tenancy issue must be awaited. Therefore, the forcible entry case was dismissed without prejudice, pending the final outcome of the tenancy case.