Domingo, Jr. v. Ordonio, Jr.
CLARIFICATIONFacts
1. The Antecedents: Petitioners Ernesto Domingo, Jr. et al. are the registered owners of several parcels of agricultural land in Tumiao, Lambayong, Sultan Kudarat, covered by Transfer Certificates of Title (TCTs) issued pursuant to Emancipation Patents (EPs). They alleged that on February 4, 2017, and April 1, 2017, respondents Ernesto Ordonio, Jr. et al., accompanied by armed men, entered the properties through force and intimidation, even firing shots at the petitioners. Respondents countered that the petitioners' EPs had been declared null and void by the Department of Agrarian Reform Adjudication Board (DARAB) in a 2004 decision that had long become final, and that they (respondents) were the adjudged owners. 2. Procedural History: Petitioners filed a Complaint for Forcible Entry with a prayer for Preliminary Mandatory Injunction before the Municipal Circuit Trial Court (MCTC). The MCTC ruled in favor of the petitioners, finding they had prior physical possession and that the issue of ownership was not the primary concern in a forcible entry suit. The Regional Trial Court (RTC) affirmed the MCTC. However, the Court of Appeals (CA) reversed the lower courts, ruling that the case was agrarian in nature and should have been referred to the Department of Agrarian Reform (DAR) pursuant to Republic Act No. 9700, as both parties alleged agrarian issues and were farmers. 3. The Petition: Petitioners filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court. They argue that the MCTC correctly exercised jurisdiction because the case is a simple forcible entry suit and does not involve an agrarian dispute. Respondents maintain that the CA was correct in dismissing the case for lack of jurisdiction, asserting that the controversy involves the implementation of the Comprehensive Agrarian Reform Program (CARP) and the validity of Emancipation Patents.
Issue(s)
Whether the Petition is procedurally defective due to the lack of competent evidence of identity in the verification and certification of non-forum shopping. Whether the Municipal Circuit Trial Court (MCTC) has jurisdiction over the Complaint for Forcible Entry or if the case must be automatically referred to the Department of Agrarian Reform (DAR) as an agrarian dispute under Republic Act No. 9700.
Ruling
The Supreme Court GRANTED the Petition, REVERSED the Court of Appeals' Decision, and REINSTATED the MCTC and RTC rulings in favor of the petitioners.
Ratio Decidendi
On Issue 1: The Petition is not procedurally defective despite the lack of official identification documents in the verification and certification of non-forum shopping. Under Rule II, Section 6 of the 2004 Rules of Notarial Practice, a 'jurat' is valid if the individual is personally known to the notary public, in which case the presentation of competent evidence of identity is not required. The Court noted that the affiants in this case were personally known to the Notary Public who notarized the documents. Applying the ruling in Jandoquile v. Revilla, Jr., the Court held that if the notary knows the affiants personally, they need not show valid identification cards. Furthermore, following Coca-Cola Bottlers v. De la Cruz, the Court emphasized that minor defects in notarization should not defeat a petition in the interest of justice. Therefore, the Petition complied with the rules on verification and certification against forum shopping. On Issue 2: The Municipal Circuit Trial Court (MCTC) retains jurisdiction because the case does not constitute an agrarian dispute requiring automatic referral to the Department of Agrarian Reform (DAR). The Court clarified that Section 19 of Republic Act No. 9700 requires automatic referral only when there is an allegation that the case is agrarian in nature and one party is a farmer, farmworker, or tenant. However, a 'mere allegation' or bare statement in the pleadings is insufficient; the pleadings must clearly show the existence of the elements of an agrarian dispute to avoid unnecessary delays. Citing Bumagat v. Arribay, the Court reiterated that an essential element of an agrarian dispute is the existence of a tenancy relationship between the parties. In this case, no tenancy relationship exists because both parties are claiming ownership of the subject properties—the petitioners based on their Transfer Certificates of Title and the respondents based on a prior DARAB decision. Since the elements of tenancy (consent, sharing of harvest, etc.) are absent, the controversy is a regular possessory action for forcible entry, which falls under the jurisdiction of the first-level courts.
Main Doctrine
The Supreme Court clarifies that the 'allegation' required under Section 19 of Republic Act No. 9700 (Comprehensive Agrarian Reform Law (CARL) amendments) to trigger the automatic referral of a case to the Department of Agrarian Reform (DAR) must be substantiated by facts in the pleadings that clearly demonstrate the elements of an agrarian dispute. A 'mere allegation' or a simple statement that a case is 'agrarian in nature' is insufficient to divest regular courts of jurisdiction. Furthermore, the Court reiterates that a tenancy relationship is an indispensable element of an agrarian dispute; if the parties are both asserting ownership rather than a landlord-tenant relationship, the controversy is not agrarian, and the first-level courts retain jurisdiction over summary possessory actions.