G.R. No. 183923 , November 27, 2013
Generoso Enesio, Petitioner, vs. Lilia Tulop, substituted by her heirs, namely: Milagros T. Asia, Matthew N. Tulop and Restituto N. Tulop, Jr., Respondents.

FACTS

Lilia Tulop filed an ejectment case against Generoso Enesio before the Municipal Trial Court (MTC), alleging she was the owner of a lot he occupied by her mere tolerance. She demanded he vacate the premises as she needed the property for a store. Enesio, in his Answer, claimed he was an agricultural tenant, asserting the case was an agrarian dispute under the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB), and thus the MTC lacked jurisdiction.
During the pre-trial conference, the parties stipulated to key facts: Enesio was not a registered tenant; he occupied the lot and had recently planted bananas; he had been occupying the land as a tenant with the consent of the previous owner, Gregorio Navarro (Lilia’s father); he had never given any share of the harvest to Lilia but had shared harvests with the previous owner and later with the caretaker, Margarita Navarro, and Emilio Navarro; and Lilia’s title to the lot was issued in December 1994.

ISSUE

Whether the MTC correctly exercised jurisdiction over the ejectment case despite the defense of tenancy raised by the petitioner.

RULING

The Supreme Court affirmed the lower courts’ rulings, denying the petition. The Court held that the MTC properly exercised jurisdiction. The mere allegation of a tenancy relationship does not automatically divest the MTC of jurisdiction over an ejectment case. The MTC must first hear and receive evidence to determine if such a relationship truly exists. In this case, the MTC complied with the proper summary procedure for ejectment under the Revised Rules on Summary Procedure, which primarily requires the submission of affidavits and position papers, with hearings conducted only when necessary to clarify facts.
Based on the evidence submitted, particularly the stipulation of facts, the MTC correctly found that no tenancy relationship existed between Enesio and Lilia Tulop. A fundamental element of agricultural tenancy—the sharing of harvests between the landowner and the tenant—was absent. Enesio admitted he never shared any harvest with Lilia. His sharing with previous owners or their caretakers did not establish a tenancy relationship with Lilia, the current titled owner. Furthermore, the petitioner’s new argument on appeal—that Lilia must respect a supposed tenancy relationship with her predecessor-in-interest under Section 10 of Republic Act No. 3844 —was raised too late and could not be considered for the first time at the Supreme Court. Thus, with no tenancy proven, the MTC validly adjudicated the ejectment case.