People v. Bacar
REITERATIONFacts
The Antecedents: Roberto Bacar and Michael Mercado, who had filed a petition for reinstatement of their tenancy status against Vicente Tan before the Department of Agrarian Reform Adjudication Board (DARAB), were subsequently charged with Qualified Theft before the Regional Trial Court (RTC). Bacar was accused of stealing two sacks of copra valued at PhP1,400.00, while Mercado was accused of stealing one sack of copra valued at PhP711.00. Both individuals pleaded not guilty to the charges. The DARAB, in its decision, declared Bacar and Mercado as de jure tenants over the landholdings owned by Tan, entitling them to reinstatement and peaceful possession. Procedural History: Following the DARAB's declaration of their tenancy status, both Bacar and Mercado filed Motions to Quash the Informations before the RTC, arguing that the criminal cases involved agrarian disputes and thus fell under the exclusive jurisdiction of the DAR. The RTC denied these motions, asserting its jurisdiction over the Qualified Theft charges. Bacar and Mercado separately appealed to the Court of Appeals (CA). In G.R. No. 226098, the CA affirmed the RTC's denial of Bacar's motion. However, in G.R. No. 233817, the CA reversed the RTC's denial of Mercado's motion, ordering the RTC to refer the case to the DARAB. The People of the Philippines, through the Office of the Solicitor General, moved for reconsideration in Mercado's case, which was denied by the CA. The Petition: Roberto Bacar filed a Petition for Review on Certiorari with this Court (G.R. No. 226098), arguing that the CA erred in dismissing his petition and that the RTC lacked jurisdiction due to the agrarian nature of the dispute. He sought the dismissal of the criminal case against him. Vicente Tan, in turn, filed his own Petition for Review on Certiorari (G.R. No. 233817), assailing the CA's ruling in Mercado's case and arguing that the RTC has jurisdiction over the Qualified Theft charges. Tan prayed for the consolidation of both petitions and for the RTC to continue hearing the criminal cases. The core issue before the Supreme Court is whether the RTC has jurisdiction to hear Qualified Theft cases when the accused have been declared de jure tenants by the DARAB, thereby raising an agrarian dispute.
Issue(s)
Whether the Regional Trial Court (RTC) has jurisdiction to hear and decide the criminal cases of Qualified Theft filed against Roberto Bacar and Michael Mercado, considering the DARAB Decision declaring them as tenants de jure, and whether the DARAB's findings on tenancy affect the element of unlawful taking in the theft charges. Whether the cases involving Qualified Theft of copra from a plantation, where the accused are declared tenants de jure by the DARAB, constitute agrarian disputes that fall under the exclusive jurisdiction of the Department of Agrarian Reform (DAR), warranting the dismissal of the criminal cases.
Ruling
The Supreme Court granted the Petition in G.R. No. 226098 (Bacar) and denied the Petition in G.R. No. 233817 (Tan). It acquitted Roberto Bacar and Michael Mercado of the crime of Qualified Theft. DISPOSITIVE PORTION: WHEREFORE, the Petition for Review on Certiorari in G.R. No. 226098 is GRANTED and the Petition for Review on Certiorari in G.R. No. 233817 is DENIED. Roberto Bacar and Michael Mercado are ACQUITTED of the crime of Qualified Theft defined and penalized under Article 310 of the Revised Penal Code. Let entry of judgment be issued immediately. SO ORDERED.
Ratio Decidendi
On the issue of jurisdiction, agrarian dispute, and application of DARAB's findings: The Court reiterated that Section 50-A of R.A. No. 6657, as amended by R.A. No. 9700, mandates the automatic referral of cases to the DAR if there is an allegation that the case is agrarian in nature and one of the parties is a farmer, farmworker, or tenant. The Court found that the twin requisites were present: (1) the allegation by Bacar and Mercado that the cases involved agrarian disputes, supported by the DARAB Decision declaring them tenants de jure; and (2) their status as tenants. The DARAB Decision itself created a prima facie presumption that an agrarian dispute existed, which was not successfully rebutted by the prosecution. The Court emphasized that the DAR's findings regarding tenancy and agrarian disputes are crucial, even in criminal cases. Citing Ligtas v. People, the Court noted that a tenant's declaration by the DARAB can negate the element of unlawful taking in theft, as tenants are entitled to harvest the produce. In this case, the DARAB Decision declaring Bacar and Mercado as tenants de jure implied they had legitimate authority to harvest the copra, thus negating the element that the taking was without the owner's consent. This finding was supported by substantial evidence and had attained finality, making a referral to the DAR redundant. Therefore, the RTC was divested of jurisdiction. On the dismissal of the criminal cases: Consequently, the Court held that the essential elements of Qualified Theft were not established. Specifically, the element of taking the property without the owner's consent was negated by the DARAB's declaration of tenancy. The Court found that the DARAB Decision deserved respect and was binding, as it was supported by substantial evidence. Therefore, the criminal cases against Bacar and Mercado for Qualified Theft had to be dismissed, and they should be acquitted.
Main Doctrine
The Regional Trial Court (RTC) is divested of jurisdiction to try criminal cases for Qualified Theft when the allegations and evidence establish an agrarian dispute, necessitating referral to the Department of Agrarian Reform (DAR) for determination, as mandated by Section 50-A of R.A. No. 6657, as amended by R.A. No. 9700. A prior determination by the DARAB declaring the accused as a tenant de jure creates a prima facie presumption of an agrarian dispute, which, if not successfully rebutted, warrants the dismissal of the criminal case for lack of jurisdiction.