SAN BEDA UNIVERSITY COLLEGE OF LAW

Labor Law 1 & Agrarian Law and Social Legislation

Atty. Mercader

CHARLES BUMAGAT, et al v. REGALADO ARRIBAY

GR NO. 194818, JUNE 9, 2014

A case involving agricultural and does not immediately qualify it as an agrarian dispute. The
mere fact that the land is agricultural does not ipso facto make the possessor an agricultural
lessee or tenant. There are conditions before he can qualify as an agricultural lessee or tenant,
and the subject being agricultural land constitutes just one condition. In order to qualify as an
agrarian dispute, there must likewise exist a tenancy relation between the parties.

FACTS:

Bumagat and other petitioners are the registered owners of agricultural land. Subsequently, they
filed a complaint before the Municipal Circuit Trial Court for forcible entry against Arribay stating
that the latter entered the former’s parcels of land and ousted them from their lawful possession,
with the aid of armed goons and through the use of intimidation and threats of physical harm.
Arribay, however, filed for the dismissal of the complaint, claiming that the said properties are
agricultural lands, which indicates that the dispute is considered an agrarian matter, hence falls
under the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board or
known as DARAB.

Municipal Agrarian Reform Office denied Arribay’s motion because he failed to prove that there is an
existing tenancy or agrarian relationship between the parties. MCTC likewise found that there
was no tenancy or other agrarian relationship present between the parties, which the RTC
affirmed. However, CA reversed the decision of RTC, claiming that the dispute was indeed
under the jurisdiction of DARAB.

ISSUE:
Whether or not the dispute falls under the jurisdiction of DARAB.

HELD:
No, the CA erred in its decision because it failed to realize the fact that as between parties,
there is no expressed or even implied tenurial agreement. It was established that the acquisition
of jurisdiction by DARAB over the case, there must be an existing tenancy relation between the
parties. Hence, for a tenancy agreement exist, it is important to consider all its indispensable
elements, such as:
1. That the parties are landowner and the tenant of agricultural lessee
2. That the subject matter of relationship is an agricultural land
3. That there is consent between the parties to the relationship
4. That the purpose of the relationship is to bring about agricultural production
5. That there is personal cultivation on the part of the tenant or agricultural lessee
6. That the harvest is shared between the landowner and the tenant or agricultural lessee.

In the case at bar, all aforementioned conditions are not present. Both parties claim
ownership over the land, hence there cannot be tenancy relationship.