GR 160118; (November, 2005) (Digest)
G.R. No. 160118 . November 22, 2005.
NORBERTO RIMASUG, JOSE POLICINA, HERIBERTO DE LEON, GENEROSO SILANG, JESUS DEL MUNDO, PAULINO OLIVARES, LEONARDO CRUZ, DIONISIO ATIENZA AND NATIVIDAD HERMOSO, Petitioners, vs. MELENCIO MARTIN, BERNARDO SANTIAGO and JUAN BAUTISTA, Respondents.
FACTS
Petitioners, who were employees or relatives of employees of San Miguel Corporation (SMC) and members of the San Miguel Cooperative Credit Union (SMCCU), acquired subdivided residential lots in Guiguinto, Bulacan, from SMCCU. Separate Transfer Certificates of Title were issued to them. Due to financial constraints, petitioners did not immediately build on the lots. They later discovered that respondents had entered and planted agricultural crops on the lots without their knowledge and consent. Petitioners demanded that respondents vacate, but respondents refused. Petitioners then filed a complaint for unlawful detainer before the Municipal Trial Court (MTC) of Guiguinto, Bulacan. Respondents claimed they were recognized agricultural tenants of the land formerly owned by SMC/SMCCU, paid lease rentals, and argued that the MTC lacked jurisdiction as the case fell under the primary jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB). The MTC denied the motion to dismiss, held it had jurisdiction, and on the merits ordered respondents’ ejectment, finding no landlord-tenant relationship with petitioners. The Regional Trial Court (RTC) affirmed the MTC decision. The Court of Appeals reversed, finding respondents to be agricultural lessees, thus concluding the MTC had no jurisdiction and dismissing the complaint.
ISSUE
Whether the Municipal Trial Court had jurisdiction over the complaint for ejectment, or whether jurisdiction properly belonged to the Department of Agrarian Reform Adjudication Board due to the alleged agricultural tenancy relationship.
RULING
The Supreme Court REVERSED the Court of Appeals decision and REINSTATED the Decision of the Regional Trial Court affirming the MTC’s judgment. The MTC had jurisdiction over the ejectment case.
The Court held that jurisdiction is determined by the material allegations in the complaint at the time of its filing. Petitioners’ complaint alleged possession de facto and a cause of action for unlawful detainer based on tolerance of occupation, which falls under the exclusive original jurisdiction of the MTC under Batas Pambansa Blg. 129, as amended. The defense of agricultural tenancy raised by respondents in their answer does not divest the MTC of jurisdiction if the complaint itself does not assert such a relationship. The essential elements of a tenancy relationship—consent, personal cultivation, and sharing of harvests—were not established to exist between petitioners and respondents. Petitioners, as registered owners, never consented to a tenancy arrangement, respondents did not share any harvest with or pay lease rentals to them, and the receipts presented by respondents pertained to payments made to the former landowner (SMCCU/SMC), not to petitioners. Therefore, no tenancy relationship was created that would place the case under the primary jurisdiction of the DARAB under the Comprehensive Agrarian Reform Law. The MTC correctly exercised jurisdiction and decided the ejectment case on its merits.