G.R. No. L-52171 August 24, 1984
Aning Sucdad and Mathew Sucdad, Jr., petitioners, vs. Judge Sergio N. Cruz, Branch II, Agrarian Court, 2nd Regional District, and Robustiano Choy, respondents.

FACTS

Robustiano Choy had been the lessee since 1949 of a 27,005-square-meter registered agricultural land in La Trinidad, Benguet, owned by petitioners Aning Sucdad and Mathew Sucdad, Jr. On January 21, 1977, Choy filed a forcible entry case (Civil Case No. 856) in the Municipal Court of La Trinidad against the Sucdads, alleging they forcibly occupied half of the land. Later that same day, the Sucdads filed an unlawful detainer case (Civil Case No. 857) against Choy, claiming his right to occupy had expired. The municipal court consolidated the two ejectment cases.
After the issues were joined, Choy moved to dismiss, asserting the Agrarian Court had jurisdiction. The municipal court initially directed referral to the Ministry of Agrarian Reform (MAR) under P.D. No. 1038. However, the MAR Regional Director certified that the cases were triable by the municipal court, as the land was planted with vegetables and Choy was not a tenant-farmer. Consequently, the municipal court ruled on October 1, 1979, that it would try the cases on the merits.

ISSUE

Whether jurisdiction over the ejectment suits lies with the Municipal Court of La Trinidad or the Agrarian Court.

RULING

The Supreme Court granted the petition, ruling that the Municipal Court of La Trinidad has exclusive jurisdiction over the consolidated ejectment suits. The legal logic is anchored on the nature of the lease and the absence of an agrarian dispute. Choy’s lease from 1949 to 1969 was a civil lease governed by the Civil Code, not an agricultural tenancy relationship under agrarian laws. An agricultural tenancy requires consent between the parties, personal cultivation by the tenant, and a sharing arrangement, which were not established here. The MAR certification, which is prima facie evidence of jurisdiction, explicitly stated the land was for vegetable planting and Choy was not a tenant-farmer, placing the case outside the Agrarian Court’s purview. Therefore, the controversy is a simple ejectment case over a civil leasehold, falling under the original jurisdiction of the municipal court for forcible entry and unlawful detainer. The Agrarian Court acted without jurisdiction in entertaining Choy’s separate action and issuing the writ of preliminary mandatory injunction. The Supreme Court made permanent its earlier restraining order, set aside the Agrarian Court’s writ, and directed the municipal court to proceed with the hearing of the ejectment cases.