G.R. No. 95664 September 13, 1991
NINA M. QUISMUNDO, petitioner, vs. HON. COURT OF APPEALS, HON. REYNALDO B. DAWAY, FELICISIMO OCAMPO, CATALINO OCAMPO, PEDRO MARQUEZ, ROMEO ENRIQUEZ and HERMINIO YUSON, respondents.

FACTS

Private respondents, as tenants of petitioner, filed a complaint on February 19, 1988, with the Regional Trial Court (RTC) of Angeles City. They prayed for a change in their tenancy relationship from share tenancy to a leasehold system under Republic Act No. 3844 , as their request had been denied by petitioner. The RTC granted their subsequent motion for court supervision of the harvesting and liquidation of sugarcane crops and later denied petitioner’s motion to dismiss the case.
Petitioner moved for reconsideration, asserting an additional ground that the RTC lacked jurisdiction over the agrarian case. She argued that under the newly enacted Comprehensive Agrarian Reform Program, specifically Executive Order No. 229 and Republic Act No. 6657 , exclusive original jurisdiction over such matters was vested in the Department of Agrarian Reform (DAR). The RTC denied her motion. The Court of Appeals upheld the RTC’s jurisdiction, ruling that the private respondents’ right to choose leasehold under R.A. No. 3844 was distinct and not divested by the subsequent agrarian laws.

ISSUE

Whether the Regional Trial Court retained jurisdiction over the complaint for conversion from share tenancy to leasehold, or if exclusive original jurisdiction was vested in the Department of Agrarian Reform by Executive Order No. 229.

RULING

The Supreme Court reversed the Court of Appeals and held that the RTC had no jurisdiction. The legal logic centers on the statutory transfer of jurisdiction effected by Executive Order No. 229, which took effect on August 29, 1987. Section 17 of E.O. No. 229 expressly vested the DAR with quasi-judicial powers and “exclusive original jurisdiction over all matters involving implementation of agrarian reform.” This provision operated as a repeal of prior laws conferring general jurisdiction over agrarian cases to courts, specifically the jurisdiction previously held by the courts of agrarian relations and later integrated into the RTCs under B.P. Blg. 129.
The Court clarified that while the complaint was filed in February 1988, after E.O. No. 229’s effectivity, the new law governed and divested the RTC of jurisdiction. Republic Act No. 6657 , enacted later in June 1988, confirmed this framework by limiting the RTC’s role in agrarian matters to specific functions as Special Agrarian Courts, primarily for determining just compensation and prosecuting certain crimes. All other agrarian reform matters, including disputes over tenancy relationships like the conversion to leasehold, fall under the DAR’s primary and exclusive original jurisdiction. Consequently, the RTC’s orders were declared void, and the case was dismissed without prejudice to its refiling with the DAR.