Alvarez v. Guanzon
REITERATIONFacts
The Antecedents: Private respondents (SPOUSES ACOT) filed an Ejectment Case against petitioner (ALVAREZ), alleging ownership of a 5.41-hectare agricultural land and a civil lease agreement with petitioner for 4.25 hectares, which expired in October 1976. Petitioner refused to vacate, claiming to be an agricultural tenant. Procedural History: The Municipal Court initially referred the case to the Department of Agrarian Reform (DAR). After an initial certification deeming the case improper for trial, an amended certification declared it proper for trial. Meanwhile, petitioner filed an Agrarian Case for maintenance of status quo and fixing of rentals, asserting a tenancy relationship. The SPOUSES denied tenancy, asserting a civil lease contract that petitioner violated by planting palay after its expiration. The Court of Agrarian Relations (CAR) denied the SPOUSES' motion to dismiss, citing P.D. No. 946. Petitioner filed an Answer in the Ejectment Case, arguing lack of jurisdiction due to the tenancy issue and the pendency of the Agrarian Case. The Municipal Court denied petitioner's Motion to Dismiss and Motion for Reconsideration. The Petition: Petitioner filed a certiorari petition seeking to annul the Municipal Court's orders, arguing that the court lacked jurisdiction over the subject matter due to the agrarian tenancy issue.
Issue(s)
Whether the Municipal Circuit Court has jurisdiction over the ejectment case despite the petitioner's claim of agricultural tenancy; specifically, the effect of a DAR certification that the case is proper for trial on the Municipal Court's jurisdiction.
Ruling
The petition for certiorari is dismissed. The Temporary Restraining Order is lifted, and the case is remanded to the Municipal Circuit Court of Murcia-Pulupandan for continuation of proceedings.
Ratio Decidendi
On the jurisdiction of the Municipal Circuit Court: The Supreme Court held that the Municipal Circuit Court retains jurisdiction over the ejectment case. The Court emphasized that the preliminary determination by the Department of Agrarian Reform (DAR) regarding the relationship between the parties is crucial. When the DAR, after referral, certifies a case as proper for trial, it signifies that the case is not exclusively an agrarian one triable by the Court of Agrarian Relations, and thus, the civil court can proceed to decide the case. The Court clarified that a defense of tenancy does not automatically divest a civil court of its jurisdiction; rather, the court has the authority to hear evidence to determine if it indeed lacks jurisdiction. The Court cited P.D. No. 946, which mandates referral to the DAR for preliminary determination of the relationship between contending parties in ejectment cases involving agricultural land, unless certified as proper for trial. The amended certification from the DAR in this case indicated that the Municipal Court could proceed. The Court reiterated that the preliminary determination by the DAR is not binding and the trial court, after hearing, may confirm, reverse, or modify it based on the evidence presented. If, upon hearing, tenancy is shown to be the real issue, the court should then dismiss the case for want of jurisdiction. Therefore, the Municipal Court was correct in denying the motion to dismiss and should proceed with the hearing to finally resolve the issue of jurisdiction based on the evidence.
Main Doctrine
A Municipal Court retains jurisdiction over an ejectment case involving a civil lease, even if a defense of agricultural tenancy is raised, provided that the Department of Agrarian Reform certifies the case as proper for trial. The Municipal Court may, after hearing, determine the existence of tenancy and dismiss the case for want of jurisdiction if such is proven.