Almazan v. Bacolod
REITERATIONFacts
The Antecedents: Petitioner Eduviges B. Almazan, one of the registered owners of a 5,865 square meter parcel of land inherited from his grandfather Agapito Almazan, discovered respondents occupying the property in 2010 and demanded they vacate. Respondents refused, claiming to be agricultural tenants as affirmed by prior Provincial Agrarian Reform Adjudicator (PARAD) and Department of Agrarian Reform Adjudication Board (DARAB) Decisions. Petitioner denied any tenurial relationship with respondents and asserted that the PARAD and DARAB Decisions were rendered against the Eranas, with whom he had no relationship. Procedural History: Petitioner filed a Complaint for Quieting of Title, Accion Reivindicatoria, and Damages before the RTC of Biñan, Laguna, arguing that the PARAD and DARAB Decisions constituted a cloud on his title. Respondents moved to dismiss, asserting that the RTC lacked jurisdiction as the case involved an agrarian dispute and sought to set aside final DARAB Decisions. The RTC denied the motion to dismiss, holding that jurisdiction is determined by the allegations in the complaint. The Court of Appeals (CA) granted respondents' petition for certiorari, annulling the RTC's orders and dismissing the complaint, finding that the ultimate relief sought was to dispossess respondents of their tenurial rights, thus falling under DARAB's jurisdiction. The CA reasoned that as the new owner, petitioner assumed the obligations of the previous owner and that the property was part of a tenanted landholding. The Petition: Petitioner filed a petition for review on certiorari, arguing that the RTC had jurisdiction over the action for quieting of title and that the CA erred in considering the respondents' defense of tenancy to dismiss the complaint. Petitioner maintained that no tenancy relationship existed between him and the respondents, and thus the PARAD and DARAB Decisions were not binding on him. He also argued that the CA erred in applying the doctrine in Relucio III v. Hon. Macaraig, Jr. as the facts were not squarely applicable.
Issue(s)
Whether the Regional Trial Court (RTC) has jurisdiction over the Complaint for quieting of title, accion reivindicatoria, and damages, considering the allegations in the complaint and the defenses raised. Whether the Court of Appeals committed grave abuse of discretion amounting to lack or excess of jurisdiction in annulling and setting aside the RTC's Orders denying the motion to dismiss, considering the DARAB's jurisdiction, the existence of a tenancy relationship, and the propriety of a special civil action for certiorari.
Ruling
The Supreme Court reversed and set aside the Decision and Resolution of the Court of Appeals, and remanded the case to the Regional Trial Court for a full resolution of the issues. The Court held that the RTC has jurisdiction over the action for quieting of title.
Ratio Decidendi
On the jurisdiction of the RTC over the action for quieting of title: The Court held that jurisdiction over the subject matter is determined by the allegations in the complaint, not by the defenses raised in the answer or motion to dismiss. The petitioner's complaint alleged that he and his co-owners are the registered owners of the subject property, that they have no tenancy relationship with the respondents, and that the PARAD and DARAB Decisions are unenforceable against them and constitute a cloud on their title. These allegations clearly make out an action to quiet title, which falls within the jurisdiction of regular courts. The purpose of an action to quiet title is to remove a cloud on one's title, which can include an apparently valid but in fact invalid or unenforceable instrument, record, claim, encumbrance, or proceeding, such as a DARAB decision that is not binding on the petitioner. The RTC, having acquired jurisdiction based on the complaint's allegations, does not lose it based on the respondents' defenses. Therefore, the CA erred in dismissing the complaint on the ground of lack of jurisdiction. On the DARAB's jurisdiction and the existence of a tenancy relationship, and the propriety of a special civil action for certiorari: The Court reiterated that the DARAB's jurisdiction is limited to agrarian disputes, and an essential requisite for its jurisdiction is the existence of a tenancy relationship between the parties. A tenancy relationship requires specific elements, including consent and sharing of harvests, which were absent in this case. The petitioner and his co-owners had no relationship with the respondents or the Eranas, against whom the PARAD and DARAB Decisions were rendered. The respondents admitted they did not know the petitioner and remitted harvest shares to individuals other than the petitioner or his predecessors. Consequently, the respondents could not claim security of tenure under Section 10 of R.A. No. 3844, as this provision applies to transferees or successors who are subrogated to the rights of their predecessors, not to strangers to the tenancy relationship. The CA's reliance on Section 10 was misplaced as there was no established link between the petitioner and the respondents' alleged former landlords. The denial of a motion to dismiss is an interlocutory order, and the general rule is that it cannot be appealed. However, a special civil action for certiorari under Rule 65 is an exception if the interlocutory order was issued with grave abuse of discretion amounting to lack or excess of jurisdiction. In this case, the RTC did not commit grave abuse of discretion in denying the motion to dismiss because it correctly determined that it had jurisdiction over the action for quieting of title based on the allegations in the complaint. Therefore, the CA erred in granting the petition for certiorari and setting aside the RTC's orders.
Main Doctrine
The Regional Trial Court (RTC) has jurisdiction over an action for quieting of title, even if the respondents claim to be agricultural tenants, if the complaint alleges that no tenancy relationship exists between the parties and that prior DARAB decisions are unenforceable against the petitioner, thus constituting a cloud on the petitioner's title. The DARAB's jurisdiction is limited to agrarian disputes, which require the existence of a tenancy relationship.