G.R. No. 166664 October 20, 2005
Domingo C. Suarez, Petitioner, vs. Leo B. Saul, Roger S. Brillo, Efrain S. Brillo, Eleno S. Brillo and Ignacio G. Pelaez, Respondents.

FACTS

Petitioner Domingo Suarez owned a 23-hectare agricultural land in South Cotabato. Respondents filed a complaint before the DARAB, alleging they were his agricultural tenants under a 25-75 sharing agreement. They claimed that after Suarez voluntarily offered the land for sale to the government under CARP, and they were identified as potential farmer-beneficiaries, they were illegally ejected when Suarez entered into a Grower Agreement with TADI (T’boli Agro-Industrial Development, Inc.). Suarez denied the tenancy relationship, asserting respondents were installed by a DAR official upon his Voluntary Offer to Sell (VOS). The Regional Adjudicator dismissed the complaint, finding respondents failed to prove tenancy and only held an inchoate right as potential beneficiaries.
The DARAB Central Office reversed the dismissal, declaring respondents as bona fide tenants and ordering their reinstatement with disturbance compensation. It held that Suarez admitted the tenancy in his answer and that any ejectment was illegal. The Court of Appeals affirmed the DARAB decision. Suarez elevated the case to the Supreme Court, contesting the existence of a tenancy relationship and the legality of the ejectment.

ISSUE

The core issues are: (1) whether respondents are bona fide agricultural tenants of petitioner, and (2) whether the DARAB had jurisdiction over the complaint.

RULING

The Supreme Court granted the petition and dismissed the complaint. On the first issue, the Court ruled that respondents failed to substantiate the existence of an agricultural tenancy relationship. The essential elements of tenancy—consent of the parties, personal cultivation, and sharing of harvests—were not proven. The alleged admission by Suarez in his answer was taken out of context; he specifically stated that respondents were installed by the DAR, not by him as landowner. No evidence was presented regarding the specific areas cultivated, crops produced, or sharing of harvests prior to the VOS. Their status was merely that of potential farmer-beneficiaries under the pending CARP coverage, which is an inchoate right insufficient to establish tenancy.
On the jurisdictional issue, the Court held that the DARAB’s jurisdiction is limited to agrarian disputes, which presuppose a tenurial relationship between the parties. Since no tenancy was proven, the complaint for reinstatement and damages did not constitute an agrarian dispute. Consequently, the DARAB had no jurisdiction over the case. Jurisdiction is conferred by law and cannot be acquired through the parties’ acts or omissions. The DARAB and the Court of Appeals thus erred in assuming jurisdiction and ruling on the merits. The Supreme Court annulled the assailed decisions and resolutions and dismissed the DARAB complaint.