GR 244433 Perlas Bernabe (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 Spouses Progedio and Teresa Cruz, filed an unlawful detainer case against respondents before the Municipal Trial Court (MTC) of Plaridel, Bulacan. Respondents alleged the case was agrarian in nature and that they were tenants. Based on this allegation, the MTC automatically referred the case to the Provincial Agrarian Reform Office (PARO) of Bulacan as required by Section 50-A of Republic Act No. 6657 , as amended. The PARO certified that the case was agrarian in nature. Consequently, the MTC dismissed the case for lack of jurisdiction. Petitioners appealed to the Regional Trial Court (RTC), challenging the MTC’s reliance on the PARO certification and arguing the absence of a tenancy relationship. The RTC upheld the dismissal, ruling the DAR certification divested the MTC of jurisdiction. The Court of Appeals (CA) affirmed the RTC’s decision. Petitioners elevated the case to the Supreme Court.
ISSUE
Whether the MTC properly dismissed the unlawful detainer case for lack of jurisdiction based solely on the PARO’s certification that the case is agrarian in nature.
RULING
No. The Supreme Court, through the concurring opinion of Justice Perlas-Bernabe, held that while the MTC’s automatic referral of the case to the PARO was proper due to the allegation of an agrarian dispute, its subsequent dismissal of the case based solely on the PARO certification was improper. The PARO’s determination that an agrarian dispute exists must be based on sufficient evidence and is subject to judicial recourse. In this case, the PARO certification lacked sufficient basis as the records were bereft of proof establishing the essential elements of a tenancy relationship, particularly consent between the parties and sharing of harvests. Respondents failed to discharge their burden of proving with substantial evidence the existence of a tenancy relationship. Therefore, the dismissal orders of the lower courts were reversed. The petition was granted, the complaint for unlawful detainer was ordered reinstated, and the case was remanded to the MTC for further proceedings.