Sarne v. Maquiling
REITERATIONFacts
The Antecedents: Private respondents, alleging to be tenants of a portion of a parcel of land owned by petitioner Laura Sarne, filed a complaint for redemption and damages. They claimed that Sarne had previously agreed to sell this tenanted portion to them and had accepted partial payment. However, Sarne subsequently sold the entire lot, including the tenanted area, to petitioners Lorenzo Jaugan, Lorenzo Jaugan, Lowena Abang-Jaugan, Pedro Jaugan, and Jenelyn Sustin-Jaugan, allegedly in contravention of the prior agreement and without notice to the tenants. The private respondents asserted their right of preemption and redemption under Sections 11 and 12 of R.A. No. 3844, the Code of Agrarian Reform. Procedural History: The private respondents initiated their claim by filing a complaint before the Department of Agrarian Reform Adjudication Board (DARAB), Office of the Provincial Adjudicator, Dumaguete City. The petitioners, including Sarne and the Jaugans, raised defenses including lack of jurisdiction, arguing that the case was not an agrarian dispute but one for specific performance, or alternatively, that it should fall under the exclusive jurisdiction of the Regional Trial Court acting as a Special Agrarian Court. They also contended that the tenancy relationship was terminated when the land was mortgaged, and that a previous case involving similar issues had been dismissed for lack of jurisdiction. The Provincial Adjudicator issued an order asserting jurisdiction, which was upheld by the Court of Appeals upon denial of the petitioners' motion for reconsideration. The appellate court found that the case involved the exercise of the right of redemption over agricultural land, thus falling within the DARAB's jurisdiction. The Petition: The petitioners are before the Supreme Court seeking reversal of the Court of Appeals' resolution. Their primary contention is that the complaint for redemption is not an agrarian case but one for specific performance, cognizable by regular courts. Alternatively, they argue that even if considered an agrarian case, the determination of just compensation involved would place it under the exclusive jurisdiction of a Special Agrarian Court. They maintain that since the landholding is not under the administration and disposition of the Department of Agrarian Reform (DAR) or the Land Bank of the Philippines, the DARAB lacks jurisdiction. The petition challenges the DARAB's authority to hear cases concerning agricultural lands not explicitly under the administration or disposition of the DAR or LBP, asserting that such matters should be handled by the regular courts or Special Agrarian Courts.
Issue(s)
Whether the complaint for redemption is an agrarian case cognizable by the DARAB or a case for specific performance cognizable by regular courts. Whether the DARAB has jurisdiction over the case, considering that the subject landholding is not under the administration and disposition of the DAR and the Land Bank of the Philippines. Whether the mortgage of the landholding to the agricultural lessee terminates the tenancy relationship; and the effect of prior dismissal and defenses on the current case.
Ruling
The petition is denied for lack of merit. The Supreme Court affirmed the Court of Appeals' resolution upholding the jurisdiction of the DARAB over the complaint for redemption.
Ratio Decidendi
On the nature of the action and jurisdiction: The Court held that the nature of an action and the jurisdiction of a body are determined by the allegations in the complaint and the character of the relief sought. The complaint alleged tenancy and sought redemption of the land under R.A. No. 3844, which clearly falls within the exclusive jurisdiction of the DARAB pursuant to Section 1(e), Rule II of the DARAB New Rules of Procedure. The Court rejected the argument that the case was for specific performance, emphasizing that the cause of action pleaded was for redemption, a matter exclusively cognizable by the DARAB. The Court reiterated that the right of redemption for agricultural lessees is statutory and arises from R.A. No. 3844, specifically Section 12, which grants the lessee the right to redeem the landholding sold to a third person without their knowledge. The Court stressed that the DARAB's jurisdiction is not limited to lands under the administration and disposition of the DAR or LBP, as the phrase "agricultural lands under the coverage of the CARP or other agrarian laws" is broad and encompasses all private lands devoted to or suitable for agriculture. The Court noted that only in paragraph (c) of Section 1, Rule II of the DARAB Rules, concerning annulment or cancellation of lease contracts or deeds of sale, is the phrase "involving lands under the administration and disposition of the DAR or LBP" used, implying that this limitation was not intended for other agrarian matters like redemption. On the DARAB's jurisdiction: The Court affirmed that the agricultural leasehold relation is protected by Section 10 of R.A. No. 3844, which states that the leasehold shall not be extinguished by the sale, alienation, or transfer of legal possession of the landholding. The Court cited jurisprudence holding that such transactions do not terminate the rights of the agricultural lessee, as these rights are enforceable against the transferee or successor-in-interest. Furthermore, Section 7 of R.A. No. 3844 provides that the leasehold relationship can only be terminated for causes provided by law, which are specified in Sections 8, 28, and 36 of the same law. The Court found that the mortgage of the landholding to the agricultural lessee is not among the causes for termination of the leasehold relationship. Therefore, the contention that respondent Romana Rafal ceased to be a tenant by reason of the mortgage had no legal basis. On the termination of tenancy and effect of prior dismissal: The Court clarified that jurisdiction is determined by the allegations in the complaint, not by the averments in the answer. The defense that the tenancy relationship did not exist or that the land was not under DAR administration does not divest the DARAB of its jurisdiction. Such defenses involve matters of proof to be presented during the proceedings. The Court also distinguished the present case from the previously dismissed DARAB Case No. VII-115-NO-97. It explained that the prior case was for Annulment of Contract of Sale and Damages, and the dismissal was based on the finding that the land was not under the administration and disposition of the DAR or LBP, which was relevant to the specific provision of Rule II, Section 1(c) of the DARAB Rules. The current case, however, is for Redemption and Damages, and its jurisdiction is anchored on Section 1(e) and 1(a) of Rule II, which covers redemption of agricultural lands and rights of persons engaged in cultivation, respectively. The Court emphasized that even if the land was not subject to distribution by the DAR, it remains under the jurisdiction of the DAR as part of the Comprehensive Agrarian Reform Program (CARP).
Main Doctrine
The DARAB has jurisdiction over cases involving the redemption of agricultural lands under agrarian laws, even if such lands are not under the administration and disposition of the DAR or LBP, as the right to redeem is a statutory right granted to agricultural lessees.