You are on page 1of 2


RUBEN ANDAL AND MIRAFLOR ANDAL (2015) The Pagpapatunay and the Sinumpaang Salaysay were voluntarily executed
Topic: RULE 70 and never impugned by the spouses Andal. Both contain express declarations
Nature of the case: Petition for Review on Certiorari that at the time Irene and her husband bought the property, the tenancy
then existing between the heirs of Teresita as former owners and the
FACTS spouses Andal as tenants had already ceased, and that no tenancy relations
Irene and Carlos Ofilada bought a 27,974 sqm parcel of land from the heirs of would continue between the latter and the new owner, Irene. Notably, the
Teresita Liwag. This was evidenced by an Extrajudicial Settlement of Estate Sinumpaang Salaysay, being a public document, is evidence of the facts in
with Absolute Sale where Miraflor Andal (respondent), who brokered the sale the clear unequivocal manner therein expressed and has in its favor the
of the property, signed as tenant. Prior to the sale, Miraflor executed a presumption of regularity. The spouses Andal are bound by their admissions
Pagpapatunay, where she stated that in exchange for P1.1M, she waives any against their own interest.
claim of her tenancy rights over the property. She executed another
Sinumpaang Salaysay with the consent of her husband two weeks after the Indeed, while a tenancy relationship cannot be extinguished by the sale,
sale, acknowledging Sps. Ofilada’s ownership over the property and waiving alienation, or transfer of the legal possession of the landholding, the same
any tenancy rights that she and her husband might have over the land. may nevertheless be terminated due to circumstances more advantageous
to the tenant and his/her family. As later disclosed by Irene during trial, such
Eight years after, Irene filed a Complaint for Ejectment and Damages against ‘sufficient consideration’ received by Miraflor amounted to P1.1 million by
Sps. Andal before the MTC of San Antonio, Quezon. Sps. Andal claimed that way of disturbance compensation, a factual allegation which was again never
they were tenants of Irene’s predecessor-in-interest and continued to be refuted by the spouses Andal before the lower court and was found to be an
such despite transfer of ownership to Irene. They contended that since the uncontroverted fact by the CA. To the Court, the said amount is adequate
suit is an action to dispossess them as tenants, it is not the MTC which has enough for the spouses Andal to relinquish their rights as tenants. In fine, it
jurisdiction over the complaint but the Department of Agrarian Reform can be reasonably concluded that the tenancy relationship between the
Adjudication Board (DARAB). previous owners and the spouses Andal had already been severed.

ISSUE: Whether jurisidiction over the case is with MTC or the DARAB. 2) On WON a new tenancy relationship between Irene and the spouses
Andal was subsequently formed. --NO
RULING: MTC has jurisdiction. For the DARAB to have jurisdiction over the case, there must be a tenancy
Rule: Forcible entry and unlawful detainer cases fall under the exclusive relationship between the parties. Evidence is necessary to prove the
original jurisdiction of the metropolitan trial courts, municipal trial courts, and allegation of tenancy.
the municipal circuit trial courts. On the other hand, the DAR is vested with
primary jurisdiction to determine and adjudicate agrarian reform matters An allegation of tenancy before the MTC does not automatically deprive the
and has exclusive original jurisdiction over all matters involving the court of its jurisdiction. Basic is the rule that x x x the material averments in
implementation of agrarian reform. As DAR’s adjudicating arm, it is the the complaint determine the jurisdiction of a court. x x x a court does not
DARAB that has exclusive and original jurisdiction involving all agrarian lose jurisdiction over an ejectment suit by the simple expedient of a party
disputes. raising as a defense therein the alleged existence of a tenancy relationship
between the parties. xxx
1) On WON the tenancy relationship between Rs and the previous owners
was already severed: --YES
The Court agrees with the conclusion of both the MTC and the RTC that for
dearth of evidence, tenurial relationship between the parties was not
sufficiently shown. Thus, the said courts correctly assumed jurisdiction over
the ejectment case.

In sum, the Court holds that absent any tenurial relationship between them,
the spouses Andal 's possession of Irene's properties was by mere tolerance of
the latter. The action to dispossess the spouses Andal there from is therefore a
clear case of summary action for ejectment cognizable by the regular courts.