GR 244433 CAguioa (Digest)
G.R. No. 244433 , April 19, 2022
ANTONIO R. CRUZ AND LORETO TERESITA CRUZ-DIMAYACYAC, AS HEIRS OF THE LATE SPOUSES DR. PROGEDIO R. CRUZ AND TERESA REYES, PETITIONERS, VS. CARLING CERVANTES AND CELIA CERVANTES SANTOS AND ALL PERSONS CLAIMING RIGHTS UNDER THEM, RESPONDENTS.
FACTS
Petitioners, heirs of the late Spouses Cruz, filed a complaint for unlawful detainer before the Municipal Trial Court (MTC) of Plaridel, Bulacan against respondents, heirs of the late Isidro Cervantes, concerning an agricultural parcel of land in Bulacan owned by Spouses Cruz. Respondents are the alleged tenants. The MTC dismissed the complaint for lack of jurisdiction based on a Certification issued by the Provincial Agrarian Reform Office (DAR-PARO) characterizing the case as an agrarian dispute cognizable by the DAR Adjudication Board (DARAB). This dismissal was affirmed by the Regional Trial Court (RTC) and the Court of Appeals (CA), prompting the petitioners to elevate the case via a Petition for Review on Certiorari.
ISSUE
The main issue is whether the dismissal of the unlawful detainer complaint was proper. This breaks down into two sub-issues: (1) whether the MTC erred in referring the complaint to the DAR-PARO for an initial determination of the nature of the dispute; and (2) whether the MTC erred in relying on the DAR-PARO’s determination to dismiss the case.
RULING
The MTC correctly referred the case to the DAR-PARO. Under Section 50-A of Republic Act No. 6657 (the Comprehensive Agrarian Reform Law), as amended by Republic Act No. 9700 , mandatory referral to the DAR is required when: (i) there is an allegation from any party that the case is agrarian in nature; and (ii) one of the parties is a farmer, farmworker, or tenant. The first requisite only requires a party’s allegation, while the second requisite requires proof of status as a farmer, farmworker, or tenant. In this case, both requisites for mandatory referral were present.
However, the MTC gravely erred in relying on the DAR-PARO’s determination to dismiss the complaint because there was a clear lack of substantial evidence to support the finding that an agrarian dispute existed. The DAR-PARO’s Certification was insufficient to establish the essential elements of a tenancy relationship or an agrarian dispute. Consequently, the dismissal of the complaint on jurisdictional grounds was unwarranted. The case should be remanded to the MTC for further proceedings.