CASE DIGEST : ROBERTO BACAR v. PEOPLE GR No. 226098, Aug 23, 2023 GAERLAN

FACTS : The case involves two consolidated petitions arising from separate criminal complaints for Qualified Theft filed by Vicente Tan against Roberto Bacar and Michael Mercado, who were accused of stealing copra from Tan's coconut plantation despite having access to the property as copra-makers. While the criminal cases were pending, the DARAB declared Bacar and Mercado as de jure tenants of Tan's agricultural land and ordered their reinstatement. Relying on this ruling, both accused argued that the criminal cases actually involved an agrarian dispute falling within the exclusive jurisdiction of the Department of Agrarian Reform (DAR) under Section 50-A of R.A. No. 6657, as amended by R.A. No. 9700, and sought to quash the Informations for lack of jurisdiction. The RTC denied their motions, ruling that the cases were ordinary prosecutions for Qualified Theft under the Revised Penal Code and did not involve the implementation of the Comprehensive Agrarian Reform Program (CARP) or any agrarian dispute. On appeal, the Court of Appeals rendered conflicting rulings: it affirmed the RTC's denial of Bacar's motion, holding that his status as a tenant did not prevent Tan from filing a criminal complaint for Qualified Theft and that the RTC retained jurisdiction over the criminal case; however, in Mercado's case, the CA ruled that the DARAB's declaration of tenancy demonstrated that the controversy was agrarian in nature and, pursuant to Section 50-A and the doctrine of primary jurisdiction, ordered the RTC to refer the case to the DARAB for determination of the existence of an agrarian dispute before proceeding. Consequently, Bacar elevated his case to the Supreme Court seeking the dismissal of the criminal case for lack of jurisdiction, while Tan challenged the CA's ruling in Mercado's case, insisting that the RTC had jurisdiction over both Qualified Theft cases and requesting the continuation of the criminal proceedings, prompting the Supreme Court to consolidate the two petitions because they arose from the same factual and legal issues.

ISSUE : WON the RTC has jurisdiction to hear and decide the case.

HELD The Supreme Court held that when a case involves the implementation of the Comprehensive Agrarian Reform Program (CARP), or when a party alleges that the case is agrarian in nature and one of the parties is a farmer, farmworker, or tenant, Section 50-A of Republic Act No. 6657, as amended by Republic Act No. 9700, mandates the automatic referral of the case to the Department of Agrarian Reform (DAR) for determination of whether an agrarian dispute exists. Jurisprudence, particularly Chailese Development Company, Inc. v. Dizon and Dayrit v. Norquillas, established that referral is mandatory when these two requisites are present. The Court also cited Office of the Court Administrator Circular No.