GR 152404; (March, 2003) (Digest)
G.R. No. 152404 ; March 28, 2003
RODOLFO ARZAGA and FRANCIS ARZAGA, petitioners, vs. SALVACION COPIAS and PRUDENCIO CALANDRIA, respondents.
FACTS
Petitioners Rodolfo and Francis Arzaga filed a complaint for recovery of possession and damages with the Regional Trial Court (RTC) of San Jose, Antique. They claimed co-ownership of Lot No. 5198 by virtue of a Certificate of Sale from a tax delinquency sale. They alleged that respondents Salvacion Copias and Prudencio Calandria entered and occupied the land without consent and refused to vacate despite demands.
In their answer, respondents asserted they were amortizing owners and tenant-beneficiaries of subdivided portions of the same lot, holding Emancipation Patents and corresponding Transfer Certificates of Title. They argued the RTC lacked jurisdiction, contending the dispute was agrarian in nature and thus fell under the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB). The RTC dismissed the case for lack of jurisdiction, a decision affirmed by the Court of Appeals.
ISSUE
Whether the Regional Trial Court has jurisdiction over the complaint for recovery of possession, or if jurisdiction properly lies with the DARAB as an agrarian dispute.
RULING
The Supreme Court ruled that the RTC has jurisdiction. Jurisdiction is determined by the allegations in the complaint, not by the defenses in the answer. The petitioners’ complaint was a simple action for recovery of possession based on their claim of ownership through a tax delinquency sale. It did not allege any tenurial, leasehold, or agricultural tenancy relationship between the parties.
For DARAB to have jurisdiction, an agrarian dispute involving a tenancy relationship must exist, requiring proof of elements such as consent between landowner and tenant, personal cultivation, and sharing of harvests. Here, no such relationship was established. The parties were both asserting ownership—petitioners through a tax sale and respondents through emancipation patents—which is inconsistent with a landlord-tenant relationship. The absence of a tenurial link between the parties or their predecessors-in-interest removed the case from the ambit of agrarian disputes. Consequently, the complaint for recovery of possession was within the regular jurisdiction of the RTC. The Court reversed the Court of Appeals and remanded the case to the RTC for reinstatement and further proceedings.