G.R. No. 175080 ; November 24, 2010
Eugenio R. Reyes, et al., Petitioners, vs. Librada F. Mauricio (deceased) and Leonida F. Mauricio, Respondents.

FACTS

Petitioner Eugenio Reyes was the registered owner of a parcel of agricultural land in Bulacan. Respondents Librada Mauricio and her daughter Leonida filed a complaint before the Department of Agrarian Reform Adjudication Board (DARAB) seeking the annulment of a “Kasunduan” (agreement) they executed with Eugenio. They alleged they were the legal heirs of Godofredo Mauricio, the lawful tenant of the land since 1936. They claimed the Kasunduan, which involved receiving P50,000.00 and purportedly relinquished their rights, was void due to Librada’s illiteracy and that it was procured through fraud, deceit, and undue influence.
Eugenio denied the existence of any tenancy relationship, asserting that Godofredo’s occupation was merely by tolerance. He argued the Kasunduan was voluntarily signed and that Librada received the monetary consideration. He also challenged the DARAB’s jurisdiction, contending that the primary action for annulment of contract fell under the jurisdiction of regular courts. The Provincial Adjudicator and, on appeal, the DARAB ruled in favor of respondents, declaring the Kasunduan void and upholding the tenancy relationship. The Court of Appeals affirmed these rulings.

ISSUE

The core issue is whether the DARAB had jurisdiction over the complaint, which hinges on the preliminary determination of whether a tenancy relationship existed between the parties.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court held that the DARAB correctly exercised jurisdiction. Jurisdiction over the case is determined by the allegations in the complaint and the nature of the relief sought. Respondents’ complaint was fundamentally an agrarian dispute, as it involved the rights and obligations of persons engaged in agriculture, including the cultivation of the land and the issuance of a leasehold contract. The action for annulment of the Kasunduan was incidental to the determination of the tenancy relationship and the consequent right to security of tenure.
On the substantive issue, the Court found no reason to disturb the factual findings of the DARAB and the Court of Appeals, which are generally conclusive and binding. The evidence, including a “Kasunduang Buwisan sa Sakahan” (leasehold contract) executed between Godofredo and Susana Reyes (Eugenio’s sister and co-owner at the time), sufficiently established a tenancy relationship. Upon the death of the original landowners, their heirs, including Eugenio, were subrogated to their rights and obligations. The subsequent Kasunduan was correctly nullified due to Librada’s inability to give intelligent consent, given her illiteracy and the circumstances of its execution, which constituted vitiated consent. Therefore, the DARAB properly maintained the respondents in peaceful possession of the landholding.