G.R. No. 227529 , June 16, 2021
EDUVIGES B. ALMAZAN, PETITIONER, VS. PERLA E. BACOLOD, DULCE E. BACOLOD, IRMA E. BACOLOD, AND BELEN E. BACOLOD, RESPONDENTS.

FACTS

Petitioner Eduviges B. Almazan, one of the registered co-owners of a parcel of land in Sta. Rosa City, Laguna, filed a Complaint for Quieting of Title, Accion Reivindicatoria, and Damages against respondents before the Regional Trial Court (RTC) of Biñan, Laguna. Petitioner claimed he discovered respondents occupying the land and demanded they vacate, but respondents refused, asserting they are agricultural tenants as affirmed by final and executory Decisions of the Provincial Agrarian Reform Adjudicator (PARAD) in 2000 and the Department of Agrarian Reform Adjudication Board (DARAB) in 2007. Petitioner denied any tenancy relationship, arguing the PARAD and DARAB Decisions were rendered against different individuals (the Eranas) with whom he has no relation, and that these Decisions constituted a cloud on his title.
Respondents filed a Motion to Dismiss, arguing the RTC lacked jurisdiction over the subject matter because the case ultimately sought to reverse the final agrarian reform decisions and dispossess them as tenants, placing it within the exclusive jurisdiction of the DARAB. The RTC denied the motion, holding jurisdiction is determined by the allegations in the complaint, which involved a real action affecting title or possession of real property within its jurisdiction. The Court of Appeals granted respondents’ Petition for Certiorari, annulled the RTC Orders, and dismissed the Complaint for lack of jurisdiction. The CA ruled that the ultimate relief sought was to dispossess the respondents as tenants, and their tenurial rights, affirmed by final DARAB decisions, attached to the land regardless of a direct relationship with the new owner, placing the case under DARAB’s jurisdiction.

ISSUE

Whether or not the Regional Trial Court has jurisdiction over the Complaint for quieting of title, accion reivindicatoria, and damages.

RULING

Yes, the Regional Trial Court has jurisdiction. The Supreme Court granted the petition and reversed the Court of Appeals Decision.
Jurisdiction over the subject matter is determined by the allegations in the complaint. The petitioner’s complaint alleged he is a registered owner, respondents are unlawfully occupying his property, and their claim of tenancy based on PARAD/DARAB Decisions against non-related parties constitutes a cloud on his title. The reliefs sought were to quiet title, recover possession, and remove a cloud on title. On its face, the complaint is a real action falling under the regular courts’ jurisdiction. For the DARAB to have jurisdiction, there must be a tenancy relationship between the parties. The existence of such a relationship is a factual issue that requires substantiation. The mere assertion of tenancy by respondents or the existence of prior DARAB decisions involving different landowners (the Eranas) does not automatically divest the RTC of jurisdiction. The petitioner specifically denied any tenurial link with the respondents or their predecessors. Therefore, the RTC must first receive evidence to determine if a tenancy relationship truly exists, as this is a jurisdictional fact. If no tenancy is proven, the RTC retains jurisdiction over the action for quieting of title. The CA erred in prematurely dismissing the case based on respondents’ unproven defense of tenancy. The case was remanded to the RTC for further proceedings to receive evidence on the existence of an agrarian relationship.