Case Digest: Antonio R. Cruz and Loreto Teresita Cruz-Dimayacyac, as Heirs of the Late Spouses Dr. Progedio R. Cruz and Teresa Reyes v. Carling Cervantes, Celia Cervantes Santos, and All Persons Claiming Rights Under Them G.R. No. 244433, April 19, 2022 Supreme Court, En Banc Ponente: Justice Ricardo R. Rosario

 

FACTS

Petitioners, the heirs of the late spouses Dr. Progedio R. Cruz and Teresa Reyes, filed a Complaint for Unlawful Detainer before the Municipal Trial Court (MTC) of Plaridel, Bulacan against respondents, alleging that the latter continued occupying the subject property despite the termination of their permission to possess it. Petitioners maintained that respondents' possession had become unlawful after they were served with a demand to vacate but refused to surrender the property.

In their Answer, respondents claimed that the controversy was agrarian in nature. They alleged that they were farmers or agricultural tenants cultivating the land and that their possession arose from an agricultural tenancy relationship. Pursuant to Section 50-A of Republic Act No. 6657 (Comprehensive Agrarian Reform Law), as amended by Republic Act No. 9700, the MTC referred the case to the Department of Agrarian Reform (DAR)-Provincial Agrarian Reform Office (PARO) for determination of whether an agrarian dispute existed.

The DAR-PARO certified that the case involved an agrarian dispute. Relying on the certification, the MTC dismissed the complaint for lack of jurisdiction. The Regional Trial Court and, subsequently, the Court of Appeals affirmed the dismissal. Petitioners then elevated the case to the Supreme Court through a Petition for Review on Certiorari under Rule 45, arguing that the lower courts improperly dismissed the complaint solely on the basis of the DAR certification.

ISSUE

Whether or not the Municipal Trial Court correctly dismissed the complaint for unlawful detainer after the DAR-PARO certified that the controversy was agrarian in nature.

Whether or not Section 50-A of Republic Act No. 6657, as amended by Republic Act No. 9700, automatically divests the trial court of jurisdiction once a case is referred to the DAR for determination of the existence of an agrarian dispute.

Whether or not the complaint for unlawful detainer should instead be reinstated and remanded for further proceedings in light of the DAR's certification.

HELD

The Supreme Court GRANTED the petition, REVERSED the Court of Appeals and Regional Trial Court, SET ASIDE the MTC's Order of dismissal, and REINSTATED the complaint for unlawful detainer. The Court held that the MTC correctly referred the case to the DAR-PARO pursuant to Section 50-A of Republic Act No. 6657, as amended by Republic Act No. 9700, because respondents alleged that the case was agrarian in nature and claimed to be farmers or tenants. The law mandates such referral whenever these allegations are present. However, the referral mechanism does not automatically authorize the trial court to dismiss the case upon receipt of the DAR certification.

The Court explained that Section 50-A of R.A. No. 6657 merely establishes a referral mechanism to enable the DAR to determine whether an agrarian dispute exists. The DAR certification is intended to guide the trial court in resolving jurisdictional issues, but it does not itself terminate the proceedings. The court must still determine, based on the pleadings, evidence, and applicable law, whether it indeed lacks jurisdiction or whether the case should proceed before it. Automatic dismissal solely because of the DAR certification is not sanctioned by the statute.

The Court further emphasized that jurisdiction is conferred by law and cannot depend solely on the characterization of a dispute by one of the parties or even by the DAR certification. The trial court must evaluate whether the essential elements of an agrarian dispute or tenancy relationship are sufficiently established. If factual matters remain unresolved, dismissal would be premature. Thus, the MTC erred in immediately dismissing the complaint without conducting the appropriate proceedings after the referral.

Accordingly, the Supreme Court ordered the reinstatement of the unlawful detainer complaint and remanded the case to the Municipal Trial Court of Plaridel, Bulacan for further proceedings. The Court clarified that the mandatory referral under Section 50-A of R.A. No. 6657, as amended by R.A. No. 9700, is a procedural safeguard to determine whether an agrarian dispute exists, not a jurisdiction-stripping mechanism that automatically results in the dismissal of ejectment cases.