Octavio v. Perovano
REITERATIONFacts
The Antecedents: Respondent Enrico Perovano filed a complaint for Forcible Entry with Damages against petitioners Zosimo Octavio and Jesus Albona, and Municipal Agrarian Reform Officer Dolores Gulmatico. Enrico alleged he is the lawful and registered owner of Lot No. 412 and that petitioners, by threat, intimidation, strategy, and stealth, entered the land, plowed it, and planted sugarcane, despite efforts to prohibit them. Procedural History: The Municipal Trial Court in Cities (MTCC) ruled in favor of Enrico, ordering petitioners to vacate the premises and pay rentals and attorney's fees. The Regional Trial Court (RTC) affirmed the MTCC decision in toto. The Court of Appeals (CA) also affirmed the RTC decision. The Petition: Petitioners appealed to the Supreme Court, raising issues on whether the landholding is covered by CARP, whether the case is agrarian in character, and whether the CA erred in affirming the RTC decision, arguing that the case involves CARP implementation, thus divesting regular courts of jurisdiction.
Issue(s)
Whether Lot 412 is covered by CARP, rendering the conveyance to Enrico Perovano and subsequent transactions void, and whether the Court of Appeals erred in affirming the RTC decision, thereby divesting the regular court of its jurisdiction. Whether the case filed by the respondent against the petitioners is tantamount to a case of disqualification of the latter as duly installed farmer-beneficiaries, hence agrarian in character.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals, holding that the action is one for ejectment and the MTCC has jurisdiction over it. The Court found that petitioners were not recognized farmer-beneficiaries and were mere usurpers of the land.
Ratio Decidendi
On the issue of jurisdiction, CARP coverage, and the Court of Appeals' decision: The Court reiterated that jurisdiction is determined by the complaint's allegations and the law at the time the action is commenced. Enrico's complaint alleged forcible entry, placing jurisdiction with the MTC under Batas Pambansa Blg. 129. While Section 50 of Rep. Act No. 6657 vests the DAR with jurisdiction over agrarian reform matters, the core issue was possession de facto, characteristic of ejectment proceedings, not an agrarian dispute. Therefore, the Court of Appeals did not err in affirming the RTC decision. On whether petitioners are farmer-beneficiaries: The Court emphasized that whether petitioners are duly installed farmer-beneficiaries is a finding of fact, and petitions for review on certiorari under Rule 45 are generally limited to questions of law. The DARAB had previously ruled that Zosimo and Jesus were not recognized farmer-beneficiaries and that their continued possession was through stealth. The MTCC also noted that petitioners lacked a CLOA and had declared themselves residents of a different lot, contradicting their claim. Therefore, their claim of being farmer-beneficiaries, which would have placed the case under DAR's jurisdiction, was unsubstantiated and contradicted by official findings.
Main Doctrine
A case involving forcible entry and unlawful detainer, where the primary issue is the physical possession of the land, falls within the exclusive original jurisdiction of the Municipal Trial Court (MTC), even if the defendant claims to be a farmer-beneficiary under the Comprehensive Agrarian Reform Program (CARP). The claim of being a farmer-beneficiary is a factual issue that does not automatically divest the regular courts of jurisdiction if the complaint itself alleges acts constituting forcible entry.