Bautista v. Villena
REITERATIONFacts
The Antecedents: The agricultural lot in question, Lot No. 26, was originally owned by Maria Lopez Caluag. The late Aquilino Villena, husband of respondent Susana Mag-isa Villena, was the original tenant-tiller of the land since 1946. In 1957, upon instruction of Caluag, Susana's house was transferred to the subject lot, which was given to her as a home lot and seedbed. Susana remained in peaceful possession until 1987 when petitioners filed an ejectment case against her. The ejectment case did not prosper. Procedural History: Petitioners filed an action for quieting of title and recovery of possession against respondent before the Regional Trial Court (RTC). The RTC ruled in favor of petitioners. Respondent appealed to the Court of Appeals (CA), which reversed the RTC decision, dismissed the complaint against respondent, and ordered the case dismissed. The CA ruled that respondent was entitled to a home lot and the right to maintain her house thereon, and that jurisdiction belonged to the DARAB, not the RTC. The Petition: Petitioners seek review of the CA's decision and resolution, questioning whether the case falls under the exclusive jurisdiction of the DARAB.
Issue(s)
Whether the case falls under the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB). Whether respondent, as a tenant, is entitled to a home lot.
Ruling
The Petition is denied. The assailed Court of Appeals Decision and Resolution are affirmed. The case is within the exclusive jurisdiction of the DARAB.
Ratio Decidendi
On the issue of DARAB's jurisdiction: The Court reiterated the doctrine of primary jurisdiction, which precludes courts from resolving controversies lodged with an administrative body of special competence. For agrarian reform cases, jurisdiction is vested in the DAR, specifically the DARAB. Executive Order 229 and Republic Act 6657 grant the DAR quasi-judicial powers and exclusive original jurisdiction over all matters involving the implementation of agrarian reform, divesting regional trial courts of such jurisdiction. Executive Order No. 129-A further created the DARAB to assume these adjudicatory powers. An agrarian dispute is defined as any controversy relating to tenurial arrangements over lands devoted to agriculture, including those concerning the terms and conditions of transfer of ownership or the right to continue and enjoy a home lot, which is an incident to the tenancy relationship. Therefore, any dispute regarding a tenant's home lot falls within the DARAB's jurisdiction. On the entitlement to a home lot: The Court affirmed that tenants are entitled to home lots, provided they are suitable and located conveniently within the landholder's property, not exceeding 1,000 square meters. This right is provided under Section 22(3) of RA 1199, as amended. The evidence presented by petitioners themselves, through the testimonies of Eugenio Bautista, Angelina G. Caluag, and Atty. Jose Caluag, established that respondent was allowed to construct her house on the subject lot in 1957 due to the Hukbalahap troubles in the farm she was tilling, making the subject lot the convenient and suitable place for dwelling at that time. The landowner acceded to this arrangement. Since the home lot was constituted in 1957, respondent can only be ejected therefrom for cause or upon proof of severance of the tenancy relationship, which grounds must be proven before the DARAB.
Main Doctrine
The Department of Agrarian Reform Adjudication Board (DARAB) has exclusive original jurisdiction over all agrarian disputes, including controversies relating to the transfer, removal, or retention of a tenant's home lot, as such matters are incidents of the tenancy relationship and fall within the implementation of agrarian laws.