G.R. No. 201631 , December 7, 2021
ANGELINA DAYRIT, REPRESENTED BY JULIE E. DAYRIT, PETITIONER, VS. JOSE I. NORQUILLAS, ET AL., RESPONDENTS.

FACTS

This case originated from a complaint for forcible entry filed by petitioner Angelina Dayrit against the respondents before the Municipal Circuit Trial Court (MCTC) of Opol and El Salvador, Misamis Oriental. The Court of Appeals (CA), in its assailed January 27, 2012 Decision and March 28, 2012 Resolution, ordered the dismissal of the Complaint for lack of jurisdiction. The CA held that the case involved an agrarian dispute, which falls under the exclusive original jurisdiction of the Department of Agrarian Reform (DAR), through its adjudicatory arm, the Department of Agrarian Reform Adjudication Board (DARAB). The petition for review on certiorari before the Supreme Court assails these CA rulings.

ISSUE

Whether the MCTC has jurisdiction over the complaint for forcible entry, or whether it is an agrarian dispute falling under the exclusive jurisdiction of the DAR.

RULING

The Supreme Court denied the Petition, affirming the dismissal of the complaint for forcible entry. The Court held that the present case is an agrarian dispute cognizable by the DAR, not the regular courts.
The ruling clarifies the interplay between the jurisdiction of first-level courts over ejectment cases under Batas Pambansa Blg. 129 and the jurisdiction of the DAR over agrarian disputes under Republic Act No. 6657 (Comprehensive Agrarian Reform Law), as amended by R.A. No. 9700 . While MTCs have exclusive original jurisdiction over forcible entry cases, this jurisdiction yields when the case involves an agrarian dispute. An “agrarian dispute” refers to any controversy relating to tenurial arrangements over lands devoted to agriculture.
The Court emphasized the mandatory referral mechanism under Section 50-A of R.A. 6657 (as inserted by R.A. 9700). This provision requires that if there is an allegation from any party that the case is agrarian in nature and one of the parties is a farmer, farmworker, or tenant, the case shall be automatically referred by the judge to the DAR. The DAR shall then determine and certify within fifteen (15) days from referral whether an agrarian dispute exists. Since the allegations in the complaint and the parties’ circumstances indicated a controversy involving tenurial arrangements over agricultural land, the case was properly deemed an agrarian dispute under the primary and exclusive jurisdiction of the DAR. Consequently, the MCTC had no jurisdiction to hear the forcible entry complaint.