G.R. No. 96882 March 12, 1996
EUTIQUIANO PAGARA, ET AL. AND THE SECRETARY OF AGRARIAN REFORM, petitioners, vs. THE HONORABLE COURT OF APPEALS, JORGE C. PADERANGA, ET AL., respondents.
FACTS
Private respondents, the Paderangas, acquired parcels of land in Zamboanga del Sur in 1967. In 1973, the Department of Agrarian Reform (DAR) placed these lands under Operation Land Transfer (OLT) and subsequently issued OLT certificates to private petitioners, who were farmer-beneficiaries. The Paderangas protested this action before the DAR, but after years of inaction, they filed a complaint in 1986 before the Regional Trial Court (RTC) of Pagadian City. They sought to recover possession, cancel the OLT certificates, and recover damages, arguing the petitioners were not bona fide tenants, were disqualified beneficiaries, and the landholding was exempt as each parcel was below five hectares. Petitioners moved to dismiss, contending the RTC lacked jurisdiction because the Paderangas failed to first secure a certification from the DAR Secretary that the case was proper for trial, as required by Presidential Decree No. 1038.
ISSUE
Whether the Regional Trial Court validly acquired jurisdiction over the complaint for recovery of possession and annulment of OLT certificates despite the absence of a prior certification from the Secretary of Agrarian Reform.
RULING
Yes, the RTC validly acquired jurisdiction. The Supreme Court affirmed the rulings of the lower courts. Presidential Decree No. 1038, which mandates a preliminary DAR determination and certification before court action for ejectment cases involving tenant-farmers in rice and corn lands, is inapplicable. The core issue was the validity of the OLT coverage and the certificates of title issued under the agrarian reform program, not an ejectment case predicated on a tenancy relationship. The Paderangas’ action was essentially one for the annulment of titles, a matter within the general jurisdiction of the RTC. Furthermore, the law itself provides that the DAR’s preliminary determination is not binding on the court. The Court also found that the petitioners failed to substantiate the existence of a tenancy relationship, which is a requisite for the application of P.D. No. 1038’s certification requirement. Since no tenancy was proven, the jurisdictional prerequisite did not attach, and the RTC correctly proceeded to adjudicate the case on its merits, ultimately finding the OLT coverage improper and ordering the cancellation of the certificates.