G.R. No. L-40533 January 31, 1978
COSME CABIO, TIMOTEO CABIO, ROBERTA CABIO and MARIA CABIO, as Heirs of Roman Cabio, petitioners, vs. BONIFACIO ALCANTARA and THE HON. COURT OF APPEALS, respondents.

FACTS

The petitioners, heirs of Roman Cabio, filed an ejectment suit against private respondent Bonifacio Alcantara before the Court of Agrarian Relations (CAR), alleging a tenancy relationship and seeking to personally cultivate the land. Alcantara, in his answer, denied being a tenant and instead asserted ownership over the landholding, claiming it as his inheritance from his mother, Victorina Almero. The CAR ruled in favor of the petitioners, declaring them as owners and Alcantara as their agricultural lessee, subject to the land reform program under Presidential Decree No. 27.
On appeal, the Court of Appeals reversed the CAR decision. The appellate court noted the CAR hearing commissioner’s finding that no tenancy relationship existed. It ruled that while the CAR had jurisdiction, it erred in declaring ownership, as such a declaration was improper when the existence of tenancy was squarely disputed by a party claiming adverse ownership. The CA further held that even if a tenancy existed, the right to eject for personal cultivation was abolished by Republic Act No. 6389 and subsequent agrarian laws.

ISSUE

Whether the Court of Agrarian Relations has jurisdiction to resolve the issue of ownership in an ejectment case where the alleged tenant denies the tenancy and asserts ownership adverse to the complainant.

RULING

Yes, the Court of Agrarian Relations retains jurisdiction and has the authority to resolve incidental issues of ownership. The Supreme Court held that jurisdiction is determined by the allegations in the complaint. The petitioners’ complaint alleged a landlord-tenant relationship, which vested jurisdiction in the CAR over the ejectment case. This jurisdiction is not divested by the defendant’s mere assertion of ownership. The Court reaffirmed the doctrine from Tuvera v. De Guzman that the CAR’s exclusive authority over dispossession cases subsists even if the tenant denies the relationship and claims ownership.
The logic is that the issue of tenancy cannot be properly resolved without first determining who has the better right of possession, which necessarily involves an inquiry into the claims of ownership. Both parties here trace their claim to Victorina Almero, making them rival claimants. The Supreme Court found that the Court of Appeals erred in not making a categorical resolution on ownership after noting facts contradicting the petitioners’ claim. Consequently, the decisions of both lower courts were set aside. The case was remanded to the CAR for further proceedings to receive evidence and definitively resolve the intertwined issues of ownership and tenancy, as such a determination is crucial for applying the correct agrarian laws.