SALAZAR vs DE LEON

FACTS:
1. Respondent De Leon is the owner of a property located at the Barrio of Munoz, Municipality of
Roxas, Isabela which is classified as unirrigated rice land.

2. Herein Petitioner Salazar is not a tenant but since they are close relatives, de Leon allowed Salazar to
cultivate the subject property without paying any rental. But with the understanding that when
respondent needs the property, Salazar will peacefully vacate and surrender the same to De Leon.

3. De Leon then demanded that Salazar vacate and surrender possession of the property to him because
he wanted to personally cultivate it. However, Salazar refused and claimed that he could acquire the
subject property from him through the DAR under the operation land transfer program of the
government.

4. This prompted Respondent De Leon to file a Complaint for recovery of possession of real property
and damages against Petitioner Salazar. Salazar was declared in default for his failure to file an answer
or any other responsive pleading to the complaint despite service of summon. Trial ensued. The RTC
rendered a decision in favor of De Leon and ordered Salazar to vacate the land and surrender the
possession to De Leon and pay De Leon the amount of the unrealized fruits of the land and reasonable
attorney’s fees.

5. Salazar filed a Motion for New Trial and Lift Order of Default alleging among other that the dispute
between him and De Leon involves a tenancy relationship over which the RTC does not have
jurisdiction. The motion was denied.

6. Aggrieved, Petitioner Salazar filed an Appeal with the CA invoking that there exists a landlord-tenant
relationship between the parties and that the RTC does not have jurisdiction. While the appeal was
pending, Salazar filed a case against De Leon before the DARAB. The DARAB then rendered a
decision finding that Salazar was a tenant of De Leon and has the right to maintain peaceful
possession and cultivation of the subject property. The decision of the DARAB was submitted to the
CA but the latter was not convinced and denied the appeal of Salazar and affirmed the decision of the
RTC.

7. So, Salazar filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court to assail the
decision of the CA. During the pendency of the Petition, the counsel for the Respondent submitted a
Manifestation that the parties had already extrajudicially settled the case between them without the
assistance of the respective counsels. Which was confirmed by the counsel of Salazar. Thus, the
counsel of De Leon prayed for the dismissal of the Petition. The court ordered the submission of the
settlement, but the parties failed to comply with the order. Instead, they filed a Motion to withdraw as
counsels alleging that their clients had already settled the case and could no longer be located because
they are already residing in the US. The Motion to withdraw was denied. The counsels then submitted
for approval the Agricultural Leasehold Contract entered by the parties. The court then denied the
Motion to Dismiss and submitted the case for resolution.

ISSUE: Is there an agrarian dispute between the parties.

SC Ruling: Yes. The dispute herein between respondent as landowner and petitioner as tenant is agrarian in
nature falling within the jurisdictional domain of the DARAB.

As a rule: The jurisdiction of a tribunal, including a quasi-judicial agency, over the subject matter of a
complaint or petition is determined by the allegations therein. However, in determining jurisdiction, it is not
only the nature of the issues or questions that is the subject of the controversy that should be determined, but
also the status or relationship of the parties. Thus, if the issues between the parties are intertwined (involved)
with the resolution of an issue within the exclusive jurisdiction of the DARAB, such dispute must be addressed
and resolved by the DARAB.

As a general rule, under Section 50 of RA 6657 otherwise known as The Comprehensive Agrarian Reform
Law it grants the DAR quasi-judicial powers among others to: determine and adjudicate agrarian reform
matters and exclusive original jurisdiction over all matters involving the implementation of agrarian reform.

Exception: Cases that falls under the exclusive jurisdiction of the Department of Agriculture (DA) and the
Department of Environment and Natural Resources (DENR).

Further, the DARAB has primary, original and appellate jurisdiction to determine and adjudicate all agrarian
disputes, cases, controversies, and matters or incidents involving the implementation of the Comprehensive
Agrarian Reform Program and other agrarian laws and their implementing rules and regulations.

An agrarian dispute has been defined as those controversy that relates to tenancy over lands devoted to
agriculture.

- In this case, it involves a controversy which involves an adverse relationship between a landlord and
his tenant. The refusal of herein Petitioner to surrender the property to the respondent is that petitioner
is allegedly his tenant, and has a right that is protected under the agrarian reform laws, a claim which
respondent denies. There is, thus, a dispute as to the nature of the relationship between respondent and
petitioner. So, the judgment rendered by the DARAB stating that Petitioner is a tenant of respondent is
vital in order for us to conclude that there is a tenancy relationship between the parties.

1. The said decision of the DARAB was not appealed by the Respondent. And consequently, has attained
the finality and constitutes res judicata on the issue of petitioner’s status as a tenant of respondent.

- Res judicata is a concept applied in the review of lower court decisions in accordance with the
Doctrine of Hierarchy of Courts. But jurisprudence has also recognized the rule of administrative res
judicata: The rule which forbids the reopening of a matter once judicially determined by
competent authority. This rule is applicable as well to the judicial and quasi-judicial facts of public,
executive or administrative officers and boards acting within their jurisdiction as to the judgments of
courts having general judicial powers. In short, it has been declared that whenever final adjudication
of persons vested with power to decide on the property and rights of the citizen is examinable by the
Supreme Court, upon a writ of error or a certiorari, such final adjudication may be pleaded as res
judicata because the findings of fact of an administrative agency are binding and conclusive upon the
Supreme Court, for as long as substantial evidence supports said factual findings.

2. As to the Agricultural Leasehold Contract executed by the parties during the pendency of the Petition
as a settlement of the controversy between the parties, although the court did not essentially view that
the said agreement is the settlement made by the parties, the court actually recognizes the same to be a
written confirmation of the tenancy relationship that has existed between the parties from the
beginning.