G.R. No. L-51901. August 31, 1984.
SIMPLICIO ALVAREZ, petitioner, vs. HON. SIXTO R. GUANZON, Judge of the Municipal Circuit Court of Murcia-Pulupandan and the SPOUSES LUIS ACOT and PURITA BLANCA ACOT, respondents.

FACTS

Private respondents, spouses Luis and Purita Acot, filed a Complaint for Illegal Detainer with Damages against petitioner Simplicio Alvarez with the Municipal Court of Murcia, Negros Occidental. They alleged they acquired ownership of an agricultural land in 1972, and that prior to their acquisition, petitioner had entered into a civil lease with their predecessor-in-interest over a portion of the lot, which lease expired in October 1976. Despite demands, petitioner refused to vacate, claiming he was an agricultural tenant. The Municipal Court, at petitioner’s instance, referred the complaint to the Department of Agrarian Reform (DAR) for a preliminary determination of the relationship.
Subsequently, petitioner filed a separate Complaint for “Maintenance of Status Quo and Fixing of Rentals” with the Court of Agrarian Relations (CAR), Bacolod City, alleging he had always been an agricultural tenant. Meanwhile, the DAR, after reinvestigation, issued an Amended Certification declaring the ejectment case “proper for trial.” In the ejectment case, petitioner moved to dismiss, arguing the Municipal Court lacked jurisdiction as an agrarian tenancy relationship was involved and a case was pending before the CAR. The Municipal Court denied the motion, prompting this certiorari petition.

ISSUE

Which court has jurisdiction over the subject matter—the Municipal Circuit Court or the Court of Agrarian Relations?

RULING

The Supreme Court ruled that the respondent Municipal Circuit Court has jurisdiction to proceed with the ejectment case. The legal logic hinges on the procedural mechanism established under Section 12 of Presidential Decree No. 946. This provision mandates that when an ejectment case involving an agricultural land is filed, it must first be referred to the Secretary of Agrarian Reform or an authorized representative for a preliminary determination of the relationship between the parties. The certification issued is not binding but is preliminary.
Here, the Municipal Court complied by referring the case to the DAR. The DAR’s Amended Certification that the case was “proper for trial” signifies, as officially interpreted, that the case is not an agrarian tenancy dispute falling under the exclusive original jurisdiction of the CAR. Consequently, the civil court (the Municipal Circuit Court) is empowered to assume jurisdiction and proceed to hear the evidence on the merits. The Court emphasized that a defense of tenancy does not automatically deprive a court of jurisdiction; rather, the court has the authority to receive evidence precisely to determine whether a tenancy relationship exists. If, after hearing, tenancy is shown to be the real issue, the court should then dismiss the case for want of jurisdiction. Therefore, the Municipal Circuit Court correctly denied the Motion to Dismiss and must continue with the proceedings, being free to confirm, reverse, or modify the DAR’s preliminary determination based on the evidence presented. The Petition for certiorari was dismissed.