Mendoza v. Germino
REITERATIONFacts
The Antecedents: Petitioners Jose Mendoza and Aurora C. Mendoza filed a complaint for forcible entry against respondent Narciso Germino before the Municipal Trial Court (MTC) of Sta. Rosa, Nueva Ecija. They alleged they were the registered owners of a five-hectare parcel of land and that Narciso unlawfully entered the property by means of strategy and stealth without their consent. Narciso, in his answer, claimed he was merely helping his brother, Benigno Germino, who was the plaintiffs' agricultural lessee. The plaintiffs then moved to remand the case to the Department of Agrarian Reform Adjudication Board (DARAB) due to the tenancy issue. The MTC, without hearing and despite objection, ordered the remand to DARAB. Procedural History: Plaintiffs filed an amended complaint with the Provincial Agrarian Reform Adjudicator (PARAD), impleading Benigno Germino. They alleged that Benigno unlawfully entered the property in 1982/1983 through strategy and stealth, withheld possession until 1987, appropriated its produce, and then transferred possession to Narciso, who also refused to return possession and appropriated the produce. They prayed for damages (13,000 cavans of palay or its monetary equivalent), return of possession, and attorney's fees. Respondents denied the allegations, claiming a sale agreement and partial payment, and asserted jurisdiction belonged to the Regional Trial Court (RTC). The PARAD ruled that respondents were usurpers and ordered them to vacate and pay 500 cavans of palay as damages. Respondents appealed to the DARAB, arguing the MTC's referral was void due to the repeal of P.D. No. 316 by R.A. No. 6657. The DARAB affirmed the PARAD decision, holding it acquired jurisdiction due to the amended complaint alleging an agrarian dispute. The Court of Appeals (CA) set aside the DARAB decision, finding the MTC erred in transferring the case as the original complaint was for forcible entry, and the amended complaint did not confer jurisdiction on DARAB. The CA remanded the case to the MTC. The Petition: Petitioners filed the present petition for review on certiorari, insisting that jurisdiction lies with the DARAB since the nature of the action and the allegations of the complaint show an agrarian dispute.
Issue(s)
Whether the MTC or the DARAB has jurisdiction over the case. Whether the allegation of tenancy as an affirmative defense in an answer divests the MTC of jurisdiction over a forcible entry case. Whether the amendment of a complaint can confer jurisdiction on a tribunal that did not have it initially.
Ruling
The petition is denied. The Court of Appeals did not commit reversible error in setting aside the DARAB decision and remanding the case to the MTC. The jurisdiction of a court is determined by the allegations in the complaint, not by the defenses raised by the defendant. Since the original complaint clearly alleged forcible entry, the MTC had jurisdiction. The subsequent claim of tenancy by the respondent did not automatically divest the MTC of its authority to determine if it had jurisdiction to proceed with the case. The MTC's referral to DARAB without a hearing was contrary to procedure, and the amendment of the complaint did not confer jurisdiction on the DARAB as the original action was for forcible entry.
Ratio Decidendi
On the jurisdiction of the MTC versus DARAB: The Court reiterated the basic rule that jurisdiction over the subject matter is determined by the allegations in the complaint, as provided by the Constitution and the law, and cannot be conferred by the parties. Under Batas Pambansa Blg. 129, as amended by R.A. No. 7691, the MTC has exclusive original jurisdiction over cases of forcible entry and unlawful detainer, governed by the Revised Rules on Summary Procedure (RRSP). Conversely, the DARAB has primary and exclusive jurisdiction over agrarian disputes involving the Comprehensive Agrarian Reform Program (CARP) and other agrarian laws. An agrarian dispute requires specific elements of a tenancy relationship, including parties being landowner and tenant, agricultural land as subject, consent, agricultural production purpose, personal cultivation, and sharing of harvest or rental payment. On the effect of the tenancy allegation as a defense: The Court held that respondent Narciso's averment of tenancy as an affirmative and/or special defense in his answer did not automatically divest the MTC of its jurisdiction over the forcible entry complaint. The MTC retained the authority to hear the case to determine whether it had jurisdiction to dispose of the ejectment suit on its merits. Jurisdiction is not affected by the pleas or theories set up by the defendant in an answer or motion to dismiss, as this would make jurisdiction dependent on the defendant's whims. Under the RRSP, the MTC is duty-bound to conduct a preliminary conference and, if necessary, receive evidence to ascertain if tenancy is the real issue. The Court also found that the MTC erred in immediately referring the case to the DARAB without conducting a preliminary conference, which was contrary to the rules. Furthermore, Section 2 of P.D. No. 316, which mandated the referral of land dispute cases to the Department of Agrarian Reform for preliminary determination of tenancy, had been repealed by Section 76 of R.A. No. 6657 in 1988. Therefore, the referral itself was procedurally flawed and legally unsupported at that time. On the effect of the amended complaint: The Court clarified that neither did the amendment of the complaint confer jurisdiction on the DARAB. The amended complaint still alleged that the subject property was taken by respondents through strategy and stealth, without the plaintiffs' knowledge and consent. In the absence of any allegation of a tenancy relationship between the parties in the amended complaint, the action remained one for recovery of possession of real property, which falls within the jurisdiction of the regular courts, not the DARAB. The CA correctly recognized that the material allegations and reliefs sought in the original complaint pointed to forcible entry. Consequently, the Court found that the CA committed no reversible error in setting aside the DARAB decision. While acknowledging the prolonged pendency of the case, the Supreme Court stated it was not in a position to resolve the dispute as the evidence required in regular courts differs from that of administrative agencies. Thus, the case was correctly remanded to the MTC for further proceedings.
Main Doctrine
Jurisdiction is determined by the allegations in the complaint, and the mere averment of tenancy as a defense in an answer does not divest the Municipal Trial Court (MTC) of its jurisdiction over a forcible entry case; the MTC must first determine if it has jurisdiction to dispose of the ejectment suit on its merits. Furthermore, the amendment of a complaint does not confer jurisdiction on a tribunal if it did not have jurisdiction at the time the action was originally filed.