De la Cruz v. Bautista
REITERATIONFacts
The Antecedents: Private respondent Jose I. Robles filed a complaint for ejectment against petitioners Fortunato de la Cruz and Diega Ramos-de la Cruz before the Municipal Court of Obando. Robles alleged that he was the owner of two parcels of land where petitioners had built a residential house and other improvements with his consent and tolerance. He demanded they vacate, but they refused. Procedural History: Petitioners moved to dismiss, claiming a tenancy relationship since 1941 and that the case fell under the exclusive jurisdiction of the Court of Agrarian Relations. The municipal court denied the motion, stating the complaint did not allege tenancy and thus it had jurisdiction. Petitioners filed an answer reiterating their tenancy claim and alleging a pending case before the Court of Agrarian Relations. They filed a second motion to dismiss, arguing that even if tenancy is a defense, if it's the real issue, the case should be dismissed. The municipal court rendered a decision ordering petitioners to vacate, pay rentals, and attorney's fees. Petitioners appealed to the Court of First Instance (CFI), which affirmed the municipal court's decision, except for attorney's fees. A writ of execution was issued. Petitioners then moved for referral to the Secretary of Agrarian Reform, which the CFI denied. The present petition assails this denial. The Petition: Petitioners seek to annul the CFI's denial of their motion to refer the case to the Secretary of Agrarian Reform, arguing that the court should not have taken cognizance of the ejectment case without such certification.
Issue(s)
Whether the Court of First Instance erred in denying the motion to refer the ejectment case to the Secretary of Agrarian Reform, considering the nature of the land and the alleged tenancy relationship. Whether Presidential Decree No. 316 mandates referral to the Secretary of Agrarian Reform when the land is residential, or when a tenancy relationship has been extinguished by voluntary surrender.
Ruling
The Supreme Court affirmed the order of the respondent Court of First Instance denying the motion for referral. The temporary restraining order issued by the Supreme Court was lifted.
Ratio Decidendi
On the issue of referral to the Secretary of Agrarian Reform, considering the nature of the land and the alleged tenancy relationship: The Court held that the motion to refer the ejectment case to the Secretary of Agrarian Reform was properly denied. Presidential Decree No. 316 mandates referral only for ejectment cases involving agricultural land primarily devoted to rice and corn, or where a tenancy relationship is alleged. In this case, the evidence established that the subject parcels of land were residential in nature, not agricultural. Therefore, the case did not fall within the purview of Presidential Decree No. 316, and the mandatory referral provision could not be invoked. The Court reiterated the principle that the material averments in the complaint determine jurisdiction, and a mere allegation of tenancy as a defense does not automatically divest the court of its jurisdiction over an ejectment case. The court has the authority to hear evidence to determine the tenability of the tenancy claim. On the issue of whether Presidential Decree No. 316 mandates referral when the land is residential, or when a tenancy relationship has been extinguished by voluntary surrender: The Court found that the tenancy relationship, if any, was terminated by the voluntary surrender of the landholding by the petitioners. Section 8 of Republic Act No. 3844 provides that the agricultural leasehold relation is extinguished by voluntary surrender. While parties may attach conditions to such surrender, the Court found no evidence that such a condition, as claimed by the petitioners, was agreed upon. The petitioners' act of allowing the purchase of an adjoining lot and their promise to transfer their house there further indicated a surrender of the landholding, negating their claim of continued tenancy. Consequently, with the termination of the tenancy relationship, the land ceased to be within the contemplation of Presidential Decree No. 316, rendering the referral requirement inapplicable. The Court also clarified that Memorandum Circular No. 29, Series of 1973, which speaks of referral for cases involving "actual tiller" or "tenant-farmer," does not apply when no tenancy relationship exists, as the essential requisites for tenancy were not met in this case, particularly the nature of the land as residential.
Main Doctrine
The mandatory referral of ejectment cases to the Secretary of Agrarian Reform under Presidential Decree No. 316 is not required when the subject land is residential, not agricultural, or when the tenancy relationship has been terminated by voluntary surrender.