Sindico v. Diaz
REITERATIONFacts
The Antecedents: Petitioners Virgilio A. Sindico and his wife Virginia Torcuator Sindico filed a civil case for Accion Reinvindicatoria with Preliminary Mandatory Injunction before the Regional Trial Court (RTC) against respondents, spouses Felipe and Erlinda Sombrea. Petitioners alleged that Virgilio Sindico is the registered owner of a parcel of agricultural land. He allowed the parents of respondent Felipe Sombrea to cultivate the lot without sharing in the produce as assistance for the education of their cousins. After the death of Felipe Sombrea's father, Felipe continued to cultivate the lot. Despite repeated demands, respondents failed to return possession of the lot. Procedural History: Respondents filed a Motion to Dismiss, arguing that the RTC lacked jurisdiction and that the case falls under the exclusive original jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB) as it involves an agricultural land covered by the Comprehensive Agrarian Reform Program (CARP). Petitioners opposed, stating the case does not involve an agrarian dispute as there is no tenancy relationship. The RTC granted the Motion to Dismiss, holding that the issue of possession of an agricultural lot under CARP falls within DARAB's exclusive jurisdiction. The RTC denied petitioners' Motion for Reconsideration. The Petition: Petitioners filed a Petition for Review on Certiorari, questioning whether the RTC or DARAB has exclusive original jurisdiction over the case.
Issue(s)
Whether the Regional Trial Court (RTC) or the Department of Agrarian Reform Adjudication Board (DARAB) has exclusive original jurisdiction over a case for Accion Reinvindicatoria involving an agricultural land where no tenancy relationship exists, and whether the allegations in the complaint sufficiently establish an agrarian dispute that would divest the RTC of its jurisdiction.
Ruling
The petition is GRANTED. The assailed Order of the RTC granting private respondents' Motion to Dismiss is SET ASIDE. The case is remanded to the RTC for reinstatement and further proceedings.
Ratio Decidendi
On the issue of jurisdiction: The Court held that jurisdiction over the subject matter is determined by the allegations in the complaint. It is not affected by the pleas set up by the defendant in their answer or motion to dismiss. The allegations in the petitioners' complaint clearly show that the action is one for recovery of possession, not one which involves an agrarian dispute. The definition of "agrarian dispute" under Section 3(d) of Republic Act No. 6657 (CARP Law) refers to controversies relating to tenurial arrangements, such as leasehold or tenancy. Since the petitioners' action is for recovery of possession and does not involve an agrarian dispute, the RTC has jurisdiction over it. The respondents' sole basis for assailing the RTC's jurisdiction was that the subject matter is an agricultural land, and they did not deny the allegation that there is no tenancy or leasehold agreement between the parties. This absence of a tenancy or leasehold agreement unequivocally shows that there is no agrarian dispute to speak of, which would grant exclusive original jurisdiction to the DARAB. Therefore, the RTC correctly retained jurisdiction over the case.
Main Doctrine
Jurisdiction over the subject matter is determined by the allegations of the complaint, not by the pleas set up by the defendant. An action for recovery of possession of an agricultural land does not fall under the exclusive original jurisdiction of the DARAB if it does not involve an agrarian dispute as defined by law.