G.R. No. 237102, March 04, 2020
CRC 1447, INC., PETITIONER, VS. ROSALINDA CALBATEA, EDUARDO CALBATEA, RICARDO DULA, RICARDO DULA, JR., GUIDO BALUYOT, FRANCISCO LIWANAG, ARIEL CORDOVA, JOVI MANALANSAN, ROMEO ORTEGA, REYNALDO ALFONSO, DOMINADOR CALING, REMEGIO GODINES, EFREN LAGTU, RODELIO QUINTO, JONATHAN RAMOS, AND ANY AND/OR ALL PERSONS CLAIMING RIGHTS UNDER THEM, RESPONDENTS.

FACTS

A portion of an estate originally owned by Liberty Hizon Vda. De Luna and Eufemia Rivera was placed under CARP coverage in 1993. An application for conversion to industrial use was granted by the CA in 1999, subject to conditions including development within five years. Rivera sought an extension in 2004. In 2006, the property was purchased and registered under the name of petitioner CRC 1447, Inc. On October 24, 2007, the DAR denied Rivera’s petition for extension and instead directed the issuance of a Notice of Coverage over the entire estate, which petitioner received on December 11, 2008. Petitioner filed a petition to lift the Notice of Coverage before the DAR, which was denied on February 8, 2013, and a motion for reconsideration was denied on September 10, 2013. On February 26, 2014, petitioner filed a Complaint for Recovery of Possession before the RTC against respondents, who are actual occupants and potential agrarian reform beneficiaries. Respondents sought dismissal or referral to the DAR, arguing the case involves an agrarian dispute. The RTC dismissed the case for lack of jurisdiction, holding that the determination of the validity of the Notice of Coverage falls within the exclusive and primary jurisdiction of the DAR as an agrarian dispute. The CA affirmed the RTC’s dismissal.

ISSUE

Whether the courts a quo correctly dismissed the case for recovery of possession on the ground of lack of jurisdiction.

RULING

Yes. The Supreme Court affirmed the dismissal. Jurisdiction is conferred by law and determined by the allegations in the complaint and the nature of the issues. The jurisdiction of the DAR over agrarian reform matters is primary and exclusive under Section 50 of R.A. No. 6657, as amended. The DARAB has jurisdiction over cases involving the rights and obligations of persons engaged in the management, cultivation, and use of agricultural lands covered by agrarian reform laws. Here, while the complaint is for recovery of possession, it failed to mention that the subject property is an agricultural land placed under CARP coverage via a Notice of Coverage, and that respondents are actual occupants and potential agrarian reform beneficiaries. The denial of petitioner’s petition to lift the Notice of Coverage before the DAR is significant. The issues are intertwined with the resolution of matters within the exclusive jurisdiction of the DARAB, specifically the implementation of the CARP and the validity of the Notice of Coverage. Therefore, pursuant to DAR Administrative Order No. 03-11 and OCA Circular No. 62-2010, the case involves an agrarian dispute and must be referred to and resolved by the DAR. The RTC and CA correctly dismissed the case for lack of jurisdiction.