G.R. No. L-80040 September 30, 1988
ISMAEL AMORGANDA and TRINIDAD G. AMORGANDA, petitioners, vs. HONORABLE COURT OF APPEALS, ESTANISLAO SAYCON and CLARA SAYCON, respondents.

FACTS

The petitioners, spouses Amorganda, leased a fishpond from the private respondents, spouses Saycon, under a contract originally for ten years from 1977, later extended to 1997. The petitioners paid all advance rentals. In January 1986, the respondents harvested bangus and shrimps from the fishpond without the petitioners’ consent, leading to a criminal complaint for qualified theft. Subsequently, in February 1986, the respondents, allegedly with armed men, forcibly entered the fishpond and ousted the petitioners. The petitioners then filed a civil case (Civil Case No. 8794) in the Regional Trial Court (RTC) of Negros Oriental, seeking to compel the respondents to return possession and for damages, with a prayer for a writ of preliminary injunction. The RTC granted the injunction.
The respondents contested the RTC’s jurisdiction, arguing the action was for forcible entry cognizable by the Municipal Trial Court (MTC). They also claimed the Bureau of Fisheries and Aquatic Resources (BFAR) had exclusive jurisdiction because the fishpond, allegedly part of a cancelled license, had reverted to the government. The Court of Appeals annulled the RTC’s injunction order, agreeing it was a forcible entry case under MTC jurisdiction and that the petitioners failed to exhaust administrative remedies with BFAR.

ISSUE

The primary issue is whether the Regional Trial Court had jurisdiction over Civil Case No. 8794.

RULING

The Supreme Court reversed the Court of Appeals and reinstated the RTC’s order. The Court held that the action was not a simple ejectment case for forcible entry under Rule 70. The petitioners, as lessees in peaceful possession under a lease contract, were unlawfully deprived of that possession by the lessors themselves. Their complaint sought specific performance—to compel the respondents to honor the lease contract and maintain them in peaceful enjoyment—and damages. An action for specific performance, where the subject of litigation is not estimable purely in monetary terms, falls within the exclusive original jurisdiction of the RTC under Batas Pambansa Blg. 129. The monetary claims for damages were merely incidental to this principal relief.
Furthermore, the Court rejected the claim of BFAR’s exclusive jurisdiction. Citing Pitargue vs. Sorilla, the administrative authority of an agency over public lands does not deprive the regular courts of jurisdiction over possessory actions that do not directly involve alienation or disposition of the land. The dispute here was essentially a breach of contract between private parties over possessory rights, which the courts properly adjudicate. The alleged forfeiture to the government was a matter of defense to be proven during trial, not a jurisdictional bar.