Almuete v. Andres
REITERATIONFacts
The Antecedents: The underlying dispute concerns a parcel of agricultural land awarded by the National Resettlement and Rehabilitation Administration (NARRA) to petitioner Rodrigo Almuete in 1957. Almuete exclusively possessed and cultivated the land for over twenty years. However, an Agrarian Reform Technologist filed a report in 1979, falsely stating Almuete's whereabouts were unknown and that he had waived his rights due to poor health and financial hardship. This report recommended the cancellation of Almuete's award and the granting of the land to respondent Marcelo Andres, who claimed to have occupied the land since 1967 and asserted that Almuete had sold the property to Victor Masiglat, who then transferred it to Andres. Based on these representations, Andres was issued a homestead patent and subsequently, Original Certificate of Title (OCT) No. P-52521. Procedural History: Rodrigo Almuete and his daughter, Ana Almuete, filed an action for reconveyance and recovery of possession against Marcelo Andres with the Regional Trial Court (RTC). The RTC ruled in favor of the Almuetes, declaring Rodrigo Almuete the owner, ordering Andres to vacate and reconvey the title, and awarding attorney's fees. Andres did not appeal this decision, which became final and executory. Subsequently, Andres filed a petition for certiorari with the Court of Appeals (CA), claiming his counsel's failure to appeal was due to ignorance of the law. Andres argued that the RTC lacked jurisdiction, asserting that the case involved an agrarian dispute falling under the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB). The CA granted the petition, nullifying the RTC's decision and ordering the restoration of the status quo. The Almuetes moved for reconsideration, which the CA denied. The Petition: The petitioners, Rodrigo and Ana Almuete, seek review of the Court of Appeals' decision and resolution, arguing that the CA committed grave abuse of discretion. They contend that the CA erred in giving due course to Andres' petition for certiorari filed long after the RTC decision became final. Furthermore, they argue that the case was not an agrarian dispute, thus falling within the RTC's jurisdiction, and that the CA failed to consider Andres' forceful entry onto the land and the Almuetes' vested interest. The petition asserts that the RTC's decision, which declared Rodrigo Almuete the owner and ordered the reconveyance of title, was valid and should be enforced, as the dispute centered on ownership and not a tenurial arrangement.
Issue(s)
Whether the Court of Appeals erred in granting the petition for certiorari and dismissing the case filed before the Regional Trial Court. Whether the Regional Trial Court had jurisdiction over the subject matter of the case, which involved a controversy relating to ownership of farmland; and whether the action filed by the petitioners was an agrarian dispute falling under the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB). Whether the Court of Appeals erred in not considering the manner by which respondent Marcelo Andres took possession of the land; and whether the Court of Appeals erred in not honoring the vested interest of the petitioners on the parcel of land.
Ruling
The petition is impressed with merit. The assailed Decision and Resolution of the Court of Appeals in CA-G.R. SP No. 34314 are REVERSED and SET ASIDE. The Regional Trial Court of Cauayan, Isabela was competent to try and decide Civil Case No. 20-530, and its decision, having attained finality, is valid and can no longer be disturbed, except to enforce it.
Ratio Decidendi
On the use of certiorari: The Court of Appeals erred in giving due course to the special civil action for certiorari filed by respondent Marcelo Andres. A basic requisite for such action to lie is that there is no appeal, nor any plain, speedy and adequate remedy in the ordinary course of law. Certiorari is a remedy of last resort and its principal function is to keep inferior tribunals within their jurisdiction. It cannot be used as a substitute for the lost remedy of appeal, which respondent lost by his failure to appeal the RTC decision. Furthermore, while the caption of the Amended Complaint included ejectment, it is the allegations therein, not the caption, that determine the nature of the action. The allegations clearly showed that petitioners prayed for the cancellation of the certificate of title in the name of Marcelo Andres and to be declared the absolute owners of the land in dispute, which are matters of ownership and reconveyance, not solely ejectment. On the jurisdiction of the Regional Trial Court and the nature of the case: The action filed by petitioners before the trial court was for recovery of possession and reconveyance of title, which principally involved the question of ownership of the farmland. This controversy relating to ownership is beyond the ambit of the phrase "agrarian dispute." No juridical tie of landowner and tenant was alleged between petitioners and respondent, nor was there any arrangement that would characterize the relationship as an agrarian dispute. The elements indispensable to establish a tenancy relationship, as defined under Section 3(d) of Republic Act No. 6657, were not present. Therefore, the Court of Appeals gravely erred when it held that the trial court had no jurisdiction over the subject matter of the action. The action filed by petitioners was cognizable by the regular courts, and consequently, the Regional Trial Court of Cauayan, Isabela was competent to try and decide Civil Case No. 20-530. On the alleged fraud and abandonment: The trial court found that Marcelo Andres did not acquire any right over the subject property when he supposedly bought it from Victor Masiglat because Masiglat never acquired ownership from the original owner, Rodrigo Almuete. Moreover, Andres could not present any valid document to prove his acquisition. The trial court also found that Rodrigo Almuete did not abandon the subject property. Instead, the report by Leticia Gragasin of the MAR contained obviously false assertions, knowingly misleading the Regional Director into cancelling Rodrigo's award and issuing the homestead patent in favor of Marcelo Andres. Hence, the cancellation of Rodrigo Almuete's award and the issuance of the homestead patent in favor of Marcelo Andres were perpetrated through fraud. The trial court's findings of fact, having been affirmed by the Court of Appeals initially and now being reinstated by the Supreme Court, are binding.
Main Doctrine
The jurisdiction of the DARAB is limited to cases involving a tenancy relationship between the parties. A controversy relating to ownership of farmland, where parties are contending for ownership, is cognizable by regular courts, not the DARAB. Certiorari cannot be used as a substitute for the lost remedy of appeal.