Buncio v. Ramos
REITERATIONFacts
The Antecedents: Petitioner Raquel G. Dy Buncio (Buncio) filed a complaint for Accion Reinvindicatoria and Damages against respondents Leontina Sarmenta Ramos and Fernando Ramos, claiming co-ownership and unlawful possession of a parcel of land. Respondents asserted that the Regional Trial Court (RTC) lacked jurisdiction due to an existing leasehold agreement between their predecessors and Buncio's parents, alleging a tenancy relationship. Procedural History: The RTC initially issued an Order on January 30, 2008, holding that it had jurisdiction as respondents failed to prove all elements of agricultural tenancy. However, on October 28, 2010, the RTC, citing Section 50-A of Republic Act No. 6657, as amended by RA 9700, referred the case to the Department of Agrarian Reform (DAR) based on an ocular inspection and the allegation of a landowner-tenant relationship. Buncio's motion for reconsideration was denied by the RTC on June 6, 2011. The Petition: Aggrieved, Buncio filed a Petition for Certiorari with the Court of Appeals (CA), assailing the RTC's referral order and denial of her motion for reconsideration. The CA dismissed her petition on September 30, 2011, finding that certiorari was a premature remedy as she had other plain, speedy, and adequate remedies before the DAR. Buncio's motion for reconsideration was denied by the CA on March 6, 2013, leading to the instant Petition for Review on Certiorari before the Supreme Court.
Issue(s)
Whether the Court of Appeals (CA) correctly dismissed Buncio's Petition for Certiorari. Whether Buncio acquired a vested right from the RTC's January 30, 2008 Order ruling that it had jurisdiction. Whether Republic Act No. 9700 and DAR Administrative Order No. 04, Series of 2009, were given retroactive application impairing Buncio's alleged vested right.
Ruling
The Supreme Court denied the petition, affirming the CA's dismissal of Buncio's Petition for Certiorari. The Court held that the CA correctly found that Buncio availed of the wrong remedy and that the RTC properly referred the case to the DAR.
Ratio Decidendi
On the propriety of the Petition for Certiorari: The Supreme Court affirmed the CA's dismissal of Buncio's Petition for Certiorari, reiterating that such a remedy is only available when there is no plain, speedy, and adequate remedy in the ordinary course of law. Section 50-A of Republic Act No. 6657, as amended by RA 9700, mandates that cases with allegations of agrarian nature and involving a farmer, farmworker, or tenant shall be automatically referred to the DAR. The law provides that an aggrieved party has judicial recourse after the DAR's determination. Therefore, Buncio's proper recourse was to await the DARAB's resolution and then appeal any adverse decision to the CA, making her immediate resort to certiorari premature and improper. On the alleged vested right: The Court disagreed with Buncio's contention that she acquired a vested right from the RTC's January 30, 2008 Order. It emphasized that jurisdiction over the subject matter is conferred only by the Constitution or law and cannot be acquired through waiver, omission of parties, or acquiescence of the court. If, during the proceedings, it becomes apparent that the case should be properly referred to the DAR, which has jurisdiction over agrarian disputes, the trial court is duty-bound to do so. The initial finding of jurisdiction does not preclude a subsequent correction if the true nature of the dispute requires it. On the retroactive application of RA 9700 and DAR AO 04, Series of 2009: The Court found no merit in Buncio's argument that the retroactive application of RA 9700 and DAR AO 04, Series of 2009, impaired her alleged vested right. The Court noted that even prior to these issuances, provisions in RA 6657 and the 2003 DARAB Rules of Procedure already vested the DARAB with jurisdiction to adjudicate agrarian disputes. The definition of an agrarian dispute, encompassing controversies relating to tenurial arrangements like tenancy, clearly falls within the DARAB's primary and exclusive original jurisdiction. The ruling in Chailese Development Company, Inc. v. Dizon was cited to settle the issue of retroactive application of RA 9700.
Main Doctrine
A Petition for Certiorari under Rule 65 is an improper remedy when a plain, speedy, and adequate remedy, such as awaiting the determination of the Department of Agrarian Reform (DAR) and subsequently appealing its decision, is available. Furthermore, a trial court's initial finding on jurisdiction does not create a vested right that precludes a subsequent referral to the DAR if the case is subsequently determined to involve an agrarian dispute.