G.R. No. L-56540 October 31, 1984
COSME LACUESTA, plaintiff-appellant, vs. BARANGAY CASABAAN, MUNICIPALITY OF CABANGAN, PROVINCE OF ZAMBALES, and TEOFILO RONQUILLO, defendants-appellees.

FACTS

Plaintiff-appellant Cosme Lacuesta was the agricultural lessee of a landholding in Zambales. A 5,000-square-meter portion he used for palay was expropriated by defendant Barangay Casabaan for a public plaza and other facilities. The expropriation case was filed in the Court of First Instance (CFI) of Zambales on October 8, 1975, and the Barangay was placed in possession. Lacuesta was not made a party to that case.
Lacuesta subsequently filed a Complaint for Reinstatement and Damages before the Court of Agrarian Relations (CAR), claiming illegal dispossession and seeking compensation for lost harvests and moral damages. The CAR dismissed the case, citing comity and its inability to interfere with the CFI, which had first acquired jurisdiction. It also ruled Lacuesta was not entitled to actual damages or disturbance compensation under agrarian law.

ISSUE

The core legal issue is whether the CAR or the CFI had jurisdiction over the expropriation of the tenanted landholding and, consequently, over Lacuesta’s claim for damages arising from his dispossession.

RULING

The Supreme Court ruled that jurisdiction over the expropriation case was correctly with the CFI, not the CAR. While Presidential Decree No. 946 later granted the CAR exclusive jurisdiction over expropriation of tenanted agricultural lands, this law took effect only on June 17, 1976. The expropriation case was instituted on October 8, 1975, prior to the decree’s effectivity. Therefore, jurisdiction vested in the CFI, and no irregularity was found in its exercise.
However, the Court modified the CAR’s dismissal. It held that Lacuesta’s right to security of tenure deserved protection even in eminent domain proceedings. The Barangay’s procedural lapse in not including Lacuesta as a party in the expropriation case, as required by the Rules of Court, should not prejudice him. Although Lacuesta correctly admitted he was not entitled to statutory “disturbance compensation” (which applies to conversion by a landowner, not expropriation), he was entitled to compensation for the deprivation of his farmholding. His unrebutted claim for 17.5 cavans of palay annually was deemed valid. By analogy to the five-year period used for disturbance compensation, the Court awarded him this equivalent for five years. His claim for moral damages was denied for lack of proof of the Barangay’s malice or bad faith.