Doctrines:

 For Department of Agrarian Reform Adjudication Board to have jurisdiction over a case, there must exist a
tenancy relationship between the parties..

Heirs of the Late Herman Rey Santos vs. Court of Appeals, G.R. No. 109992, March 7, 2000
YNARES-SANTIAGO, J.:

FACTS:
 After a subject Land owned by Exequiel Garcia in Plaridel, Bulacan was levied for execution, it was
sold for public auction to Herman Rey Santos, who was the sole bidder. The latter registered the
sale at the ROD after respondent Exequiel Garcia failed to exercise his right of redemption.
Consequently, Garcia filed a Petition for Injunction and Damages with an application for the
issuance of a preliminary injunction with the Department of Agrarian Reform Adjudication Board
(DARAB). Garcia’s prayer was to enjoin petitioner from preventing him from gathering the
mangoes from the property lest they become overripe. The DARAB then granted the respondent’s
petition, but however ordered that the proceeds be deposited with the Adjudication board.
 On May 7, 1992, private respondent Garcia then also filed a complaint for Annulment/Cancellation
of Sale and Document, Redemption with Damages and Preliminary Writ of Injunction against
Herman Rey Santos, the Deputy Sheriff of Bulacan and the Register of Deeds of Bulacan, before
the RTC.
 Thereafter, a certain Pantaleon Antonio also filed a motion to intervene with the DARAB claiming
that his rights and interests were also affected as he was the party who tended and had the mango
trees bear fruits this season. The DARAB suspended the hearing for the motion to intervene, but
when Antonio filed a Motion to Withdraw Intervenor’s deposited share, the DARAB granted it, thus
allowing him to withdraw P87,300 out of the P174,600.00 harvest proceeds. This was granted by
the DARAB in recognition of Antonio as the duly constituted tenant of the subject land.
 Following the DARAB’s orders which allowed the gathering of the mangoes and the proceeds
deposited by respondent, as well as granting the withdrawal of intervenor’s share by Antonio, the
heirs of Herman Santos now assailed the said orders before the Court of Appeals. However, the CA
affirmed the DARAB’s orders. Hence, the instant petition.
 In this petition, the heirs of Santos argued that the DARAB had no jurisdiction over the
case, as there was no agrarian dispute involved. Petitioners averred that the DARAB erred in
ruling over the case, as it in fact already admitted the issue on involvement of ownership, since it
has indefinitely suspended the hearing of the main case, pending the outcome of the issue of
ownership before the RTC. It further argued that the DARAB also erred in allowing the release of
the proceeds of the sale of the harvested fruits in favor of intervenor, Antonio without due process,
during the supposed indefinite suspension, and worse, without requiring said purported intervenor
to post a bond that will answer for damages that may be sustained by herein petitioners.
Therefore, it also follows that the DARAB erred in allowing respondent to gather the mango fruits,
since his ownership of the subject land was still in issue before the lower court.

ISSUE/S:
Whether or not the DARAB had jurisdiction to issue the said orders in:
1) Granting the gathering of mangoes by respondent, pending the issue of ownership case
before the RTC.
2) Granting the withdrawal of Antonio of his intervenor’s share, in view of him being an
agricultural tenant.

RULING:
No.
On the 1st order:
The court held that an “Agrarian dispute" is defined under Section 3(d) of Republic Act No. 6657 (CARP
Law), as:
 (d) 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 this Act 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.
Clearly, no agrarian dispute is involved in this case. In fact, Santos and Garcia are contending
parties for the ownership of the subject property.

In the case of Morta, Sr. v. Occidental, et al., the SC already held: For DARAB to have jurisdiction over a
case, there must exist a tenancy relationship between the parties. Its essential elements are to wit:
1. that the parties are the landowner and the tenant or agricultural lessee;
2. that the subject matter of the relationship is an agricultural land;
3. that there is consent between the parties to the relationship;

By Alena Icao-Anotado pg. 1

Doctrines:
 For Department of Agrarian Reform Adjudication Board to have jurisdiction over a case, there must exist a
tenancy relationship between the parties..

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; and
6. that the harvest is shared between the landowner and the tenant or agricultural lessee.

Also in Vda. de Tangub v. Court of Appeals (191 SCRA 885), the court held that the jurisdiction of the
Department of Agrarian Reform is limited to the following:
a) adjudication of all matters involving implementation of agrarian reform;
b) resolution of agrarian conflicts and land tenure related problems; and
c) approval and disapproval of the conversion, restructuring or readjustment of agricultural lands into
residential, commercial, industrial, and other non-agricultural uses.

In this case, Petitioners (Santos) and private respondent (Garcia) have no tenurial, leasehold, or any
agrarian relations whatsoever that could have brought this controversy under the ambit of the agrarian
reform laws. Consequently, the DARAB has no jurisdiction over the controversy and should not
have taken cognizance of Garcia’s petition for injunction in the first place.

On the 2nd order:

The issue of who can harvest the mangoes and when they can be harvested is also just an incident
ancillary to the main petition for injunction. As such, it is dependent on the main case. Inasmuch as
the DARAB has no jurisdiction to hear and decide the controversy between the parties, it also
follows that, the motion for intervention by Antonio loses the leg on which it can stand. This
issue, after all, can be resolved by the trial court, which has the jurisdiction to order the gathering of the
mango fruits and depositing the proceeds with it, considering that an action has already been filed before
it on the specific issue of ownership.

Thus in view of the foregoing, the court moved to grant the petition by setting aside the Court of Appeal
orders, and it also moved to permanently enjoin the DARAB from hearing the motion for intervention of
respondent, as well as order the return of the proceeds withdrawn by Antonio and ordering it to be
redeposited in the RTC.

By Alena Icao-Anotado pg. 2