G.R. No. 161973 November 11, 2005
FRANCISCO RAMOS, Petitioner, vs. STATELAND INVESTMENT CORPORATION, Respondent.

FACTS

Stateland Investment Corporation (SIC) acquired five parcels of land in Bulacan, including a two-storey concrete house, through a series of transactions originating from a foreclosure sale. Upon inspection, SIC found Francisco Ramos and his family occupying the house. Ramos claimed to be a tenant on the land since 1974 and asserted that the house was assigned to him as a residence by the previous owner. He filed a case before the Department of Agrarian Reform Adjudication Board (DARAB) to maintain possession and for redemption. While this agrarian case was pending, SIC sent Ramos a demand letter to vacate the house. Upon his refusal, SIC filed an ejectment complaint against Ramos before the Municipal Trial Court (MTC).
In his Answer before the MTC, Ramos admitted SIC’s ownership but argued that the court lacked jurisdiction because the issue of possession was intertwined with his tenancy claim pending before the DARAB. The MTC ruled in favor of SIC, ordering Ramos to vacate and pay rentals. The Regional Trial Court affirmed this decision. On appeal, the Court of Appeals also upheld the MTC’s jurisdiction and the ejectment order.

ISSUE

Whether the MTC had jurisdiction over the ejectment case, or whether jurisdiction properly lay with the DARAB due to Ramos’s claim of tenancy.

RULING

The Supreme Court affirmed the Court of Appeals’ decision, ruling that the MTC validly exercised jurisdiction over the ejectment case. The Court explained that for the DARAB to have jurisdiction, a tenancy relationship must be proven. This requires, among other elements, consent from the landowner and that the agricultural activity be the tenant’s principal livelihood. Ramos’s mere allegation of tenancy was insufficient to divest the MTC of jurisdiction. His admission that he was occupying the house—a residential structure—and SIC’s demand for him to vacate specifically that house, framed the issue as one of unlawful detainer based on the expiration of his right to occupy. The pending DARAB case involved the agricultural land generally, but the ejectment suit specifically concerned the residential building. The Court held that the MTC could proceed independently as the action was fundamentally for recovery of possession of the house, a matter within its competence under the Rules on Summary Procedure. The existence of an agrarian dispute does not automatically bar an ejectment case when the subject is a residential dwelling and the issue of tenancy is not indubitably established.