G.R. No. 97788 May 11, 1993
TEOFILA DE LUNA, petitioner, vs. COURT OF APPEALS, CASIANO DE LUNA and FLAVIANO DE LUNA, respondents.

FACTS

Petitioner Teofila de Luna had been in peaceful and continuous possession of four hectares of land in Laguna as an agricultural tenant, with her name appearing in the DAR master list as a tenant of landholder Atty. Francisco Redor. On May 21, 1986, she filed a complaint for forcible entry (ejectment) in the Municipal Circuit Trial Court (MCTC) against her brothers, private respondents Casiano and Flaviano de Luna, alleging they dispossessed her through stealth. The MCTC initially dismissed the case, believing jurisdiction lay with the Regional Trial Court (RTC) under agrarian laws, but later set aside its order and referred the case to the DAR. Upon receiving a DAR certification that the case was proper for trial in the municipal court, the MCTC proceeded, heard the case, and rendered a decision in favor of Teofila, ordering her brothers to vacate and pay damages. Private respondents filed a petition for certiorari and prohibition with the RTC to annul the MCTC proceedings, but the RTC dismissed it, upholding the MCTC’s jurisdiction and noting certiorari was not a substitute for a lost appeal. The Court of Appeals reversed the RTC, declaring the MCTC had no jurisdiction, applying Section 21 of R.A. No. 1199 in relation to Section 23 of B.P. Blg. 129, and holding the controversy was within the exclusive jurisdiction of the RTC as successor of the Court of Agrarian Reform.

ISSUE

Whether the Municipal Circuit Trial Court (MCTC) had jurisdiction over the ejectment suit (forcible entry) filed by petitioner Teofila de Luna against her brothers, or whether jurisdiction properly belonged to the Regional Trial Court (RTC) as an agrarian court.

RULING

The Supreme Court ruled that the MCTC had jurisdiction. The Court held that where no agricultural tenancy relationship exists between the contending parties and the situation is one merely of forcible entry, the RTC acting as an agrarian court has no jurisdiction. Jurisdiction is determined by the allegations in the complaint, which here set forth a cause of action for ejectment and damages, not an agrarian dispute. The complaint averred Teofila was the registered tenant and her peaceful possession was disrupted by persons not owners of the property. The primary issue was material possession only, not possession de jure. The defense of co-tenancy raised by respondents in their answer did not divest the MCTC of jurisdiction, especially as they were not registered in the DAR master list and did not allege selection by the landowner to succeed as tenants. The DAR certification indicated no pending agrarian dispute to which this case could be consolidated. The dispute involved forcible entry only; respondents could not take the law into their own hands. The Court rejected the argument that respondents were “third persons” under Section 21 of R.A. No. 1199 , as that provision applies to disputes involving the ejectment of a tenant by the landholder, not a dispute between persons both claiming to be tenants. Therefore, the Court of Appeals decision was reversed, and the MCTC’s jurisdiction was upheld.