G.R. No. 157491 ; June 20, 2006
SPS. PROCESO AMURAO and MINERVA AMURAO, Petitioners, vs. SPS. JACINTO VILLALOBOS and HERMINIGILDA VILLALOBOS, Respondents.

FACTS

Petitioners, the Amurao spouses, purchased a parcel of agricultural land in 1987 from Ruperto Endozo. The respondents, the Villalobos spouses, were tenants cultivating the land at the time of the sale and were allowed to continue. In 1994, the parties executed a “Kasulatan Tungkol sa Lupang Pagtatayuan ng Bahay” before barangay officials. Under this agreement, respondents promised to surrender possession to petitioners when needed for personal use, and petitioners, in turn, bound themselves to give respondents a 1,000-square-meter portion of the land upon such surrender. When petitioners later demanded possession for personal use, respondents refused both to vacate and to accept the proffered portion. Petitioners filed an ejectment case with the Municipal Circuit Trial Court (MCTC).
In their defense, respondents asserted they were agricultural tenants since 1953 and had consistently paid lease rentals. They contended the “Kasulatan” was a scheme to circumvent tenancy laws and that the dispute was agrarian in nature, falling under the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB), not the regular courts. The MCTC ruled in favor of petitioners, holding the “Kasulatan” validly terminated the tenancy. The Regional Trial Court (RTC) affirmed jurisdiction but modified the judgment, ordering petitioners to formally execute a deed for the 1,000-square-meter portion.

ISSUE

Whether the regular courts or the DARAB has jurisdiction over the ejectment case.

RULING

The Supreme Court ruled that the DARAB has exclusive jurisdiction. The legal logic hinges on the characterization of the dispute as agrarian. An agrarian dispute is defined by law as any controversy relating to tenurial arrangements over agricultural lands. The Court found that the respondents’ claim of being agricultural tenants, supported by their allegation of cultivating the land and paying rentals since 1953, was not frivolous. This assertion placed the nature of their relationship with the petitioners squarely in issue.
The existence of the “Kasulatan” did not divest the dispute of its agrarian character. The Court emphasized that the legality of the termination of a tenancy relationship, or any controversy originating from such a relationship, remains an agrarian dispute. The agreement itself, which purportedly extinguished the tenancy, became the very subject of the controversy. Since the resolution of the ejectment action required a prior determination of the validity of the tenancy relationship and the “Kasulatan’s” effect on it, the case fell within the primary and exclusive jurisdiction of the DARAB. The regular courts had no jurisdiction to proceed. Thus, the Court of Appeals’ decision annulling the RTC and MCTC rulings for lack of jurisdiction was affirmed.