2S AGRA Case Digests

TOPIC Quasi- Judicial Powers of DAR AUTHOR Fajardo

CASE TITLE Isidro v Court of Appeals GR NO 105586

TICKLER DATE December 15, 1993

DOCTRINE In the absence of a tenancy relationship, the complaint for unlawful detainer is properly within the
jurisdiction of the Municipal Trial Court
FACTS Private respondent Natividad Gutierrez is the owner of a parcel of land with an area of 4.5 hectares
located in Barrio Sta. Cruz, Gapan, Nueva Ecija. In 1985, Aniceta Garcia, sister of private respondent
and also the overseer of the latter, allowed petitioner Remigio Isidro to occupy the swampy portion
of the abovementioned land, consisting of one (1) hectare, in order to augment his
(petitioner’s)income to meet his family’s needs. The occupancy of a portion of said land was subject
to the condition that petitioner would vacate the land upon demand. Petitioner occupied the land
without paying any rental and converted the same into a fishpond. In 1990, private respondent
through her overseer demanded from petitioner the return of the land, but the latter refused to vacate
and return possession of said land, claiming that he had spent effort and invested capital in converting
the same into a fishpond.

A complaint for unlawful detainer was filed by private respondent against petitioner before the
Municipal Trial Court (MTC) of Gapan, Nueva Ecija which was docketed as Civil Case No. 4120.
Petitioner set up the following defenses: (a) that the complaint was triggered by his refusal to increase
his lease rental; (b) the subject land is a fishpond and therefore is agricultural land; and (c) that lack of
formal demand to vacate exposes the complaint to dismissal for insufficiency of cause of action.

Based on an ocular inspection of the subject land, the trial court found that the land in question is a
fishpond and, thus, in a decision dated 30 May 1991, the said trial court dismissed the complaint, ruling
that the land is agricultural and therefore the dispute over it is agrarian which is under the original and
exclusive jurisdiction of the court of agrarian relations as provided in Sec. 12(a) of Republic Act No.
946 (now embodied in the Revised Rules of Procedure of the Department of Agrarian Reform
Adjudication Board). Not satisfied with the decision of the RTC, private respondent appealed to the
respondent Court of Appeals and the appeal was docketed as CA-G.R. SP No. 26671. On 27 February
1992, as earlier stated, the respondent Court of Appeals reversed and set aside the decision of the
RTC, ordering petitioner to vacate the parcel of land in question and surrender possession thereof to
private respondent, and to pay private respondent the sum of P5,000.00 as and for attorney’s fees
and expenses of litigation.
ISSUE/S WHETHER OR NOT THE MUNICIPAL TRIAL COURT HAS THE JURISDICTION IN THIS CASE.

RULING/S Yes, In the absence of a tenancy relationship, the complaint for unlawful detainer is properly within
the jurisdiction of the Municipal Trial Court.
It is basic that whether or not a court has jurisdiction over the subject matter of an action is
determined from the allegations of the complaint.

It is well settled jurisprudence that a court does not lose its jurisdiction over an unlawful detainer
case by the simple expedient of a party raising as a defense therein the alleged existence of a tenancy

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 2S AGRA Case Digests
relationship between the parties. The court continues to have the authority to hear the evidence for
the purpose precisely of determining whether or not it has jurisdiction. And upon such hearing, if
tenancy is shown to be the real issue, the court should dismiss the case for lack of jurisdiction.

An agrarian dispute refers to any controversy relating to tenurial arrangements, whether leasehold,
tenancy, stewardship or otherwise, over lands devoted to agriculture, including disputes concerning
farmworkers associations or representation of persons in negotiating, fixing, maintaining, changing
or seeking to arrange terms or conditions of such tenurial arrangements. It includes any controversy
relating to compensation of lands acquired under Republic Act No. 6657 and other terms and
conditions of transfer of ownership from landowners to farmworkers, tenants and other agrarian
reform beneficiaries, whether the disputants stand in the proximate relation of farm operator and
beneficiary, landowner and tenant, or lessor and lessee.

But a case involving an agricultural land does not automatically make such case an agrarian dispute
upon which the DARAB has jurisdiction. The mere fact that the land is agricultural does not ipso facto
make the possessor an agricultural lessee or tenant. The law provides for conditions or requisites
before he can qualify as one and the land being agricultural is only one of them. The law states that
an agrarian dispute must be a controversy relating to a tenurial arrangement over lands devoted to
agriculture. And as previously mentioned, such arrangement may be leasehold, tenancy or
stewardship.

Whether or not private respondent knew of the conversion by petitioner of the idle, swampy land
into a fishpond is immaterial in this case. The fact remains that the existence of all the requisites
of a tenancy relationship was not proven by the petitioner. And in the absence of a tenancy
relationship, the complaint for unlawful detainer is properly within the jurisdiction of the Municipal
Trial Court, as provided in Sec. 33 of Batas Pambansa Blg. 129.

NOTES

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