CASE DIGEST : Eduviges B. Almazan v. Perla E. Bacolod, Dulce E. Bacolod, Irma E. Bacolod, and Belen E. Bacolod G.R. No. 227529, June 16, 2021 GAERLAN

 

FACTS

Eduviges B. Almazan was one of the registered owners of a 5,865-square-meter parcel of land located in Barangay Dita/Malitlit, Sta. Rosa City, Laguna, covered by Transfer Certificate of Title (TCT) No. T-060-2012008993. He and his co-owners inherited the property from their grandfather, Agapito Almazan. When Almazan visited the property in 2010, he discovered that respondents Perla Bacolod and her co-respondents were occupying the land. When asked to vacate, respondents refused and claimed that they were agricultural tenants of the property.

Respondents relied on previous decisions issued by the Provincial Agrarian Reform Adjudicator (PARAD) and the Department of Agrarian Reform Adjudication Board (DARAB), which recognized their alleged tenancy relationship with the previous occupants of the land. Almazan, however, denied the existence of any tenancy relationship between him and respondents. He argued that neither he nor his co-owners knew respondents and that the previous DARAB decisions were rendered against other individuals, specifically the Erana family, who had no relationship with him or his co-owners.

Almazan thereafter filed before the Regional Trial Court (RTC) of Biñan, Laguna a complaint for quieting of title, accion reivindicatoria, and damages. He alleged that the DARAB and PARAD decisions created a cloud over his title and possession because such decisions could not bind him as he was not a party to those proceedings. Respondents filed a motion to dismiss, arguing that the RTC had no jurisdiction because the case involved an agrarian dispute concerning their rights as tenants, which falls under the jurisdiction of the DARAB.

The RTC denied the motion to dismiss, ruling that jurisdiction is determined by the allegations in the complaint and that the case involved ownership and possession of real property. The Court of Appeals reversed the RTC and held that the DARAB had jurisdiction because the case involved the alleged dispossession of tenants. Almazan elevated the matter to the Supreme Court, questioning whether the RTC or DARAB had jurisdiction over the dispute.

ISSUE

Whether or not the RTC had jurisdiction over Almazan’s complaint for quieting of title, accion reivindicatoria, and damages despite respondents’ claim that the dispute involved an agrarian relationship falling under the jurisdiction of the DARAB.

Whether or not the existence of a tenancy relationship could be presumed based only on previous PARAD and DARAB decisions involving different parties and whether such decisions could bind Almazan as the new owner of the property.

Whether or not the Court of Appeals correctly ruled that the case should be dismissed because the DARAB had exclusive jurisdiction over the controversy involving respondents’ alleged tenurial rights.

HELD

The Supreme Court granted the petition and ruled that the RTC had jurisdiction over Almazan’s complaint. The Court held that jurisdiction over the subject matter is determined by the allegations in the complaint and the nature of the relief sought. Although respondents claimed that the case involved tenancy rights, the allegations in Almazan’s complaint showed that the main issue was the removal of a cloud on his title and the recovery of possession of property. Therefore, the action was one for quieting of title and accion reivindicatoria, which falls within the jurisdiction of the regular courts.

The Court explained that under Section 50 of Republic Act No. 6657 (Comprehensive Agrarian Reform Law of 1988), the Department of Agrarian Reform (DAR), through the DARAB, has jurisdiction over agrarian disputes involving the implementation of agrarian reform. However, for the DARAB to acquire jurisdiction, there must first be a valid tenancy relationship between the parties. A tenancy relationship cannot be presumed and must be proven by the existence of the following elements: (1) the parties are landowner and tenant; (2) the subject matter is agricultural land; (3) there is consent between the parties; (4) the purpose is agricultural production; (5) the tenant personally cultivates the land; and (6) there is sharing of harvests.

The Court ruled that respondents failed to establish a tenancy relationship with Almazan or his co-owners. The previous PARAD and DARAB decisions could not automatically bind Almazan because he was not a party to those proceedings and had no participation in creating the alleged tenancy arrangement. The Court emphasized that agrarian rights, including security of tenure, cannot be enforced against persons who never consented to the tenancy relationship. The Court also recognized that under Article 476 of the Civil Code, an owner may file an action to quiet title when there is a cloud or doubt affecting ownership rights.

Accordingly, the Supreme Court reversed the decision of the Court of Appeals and reinstated the RTC’s jurisdiction over the case. The Court held that the dispute should proceed before the RTC for a full determination of the parties’ respective rights over the property. While agrarian laws protect tenants and agrarian beneficiaries, such protection cannot extend to claims against persons who are not bound by the alleged tenancy relationship