Facts:

• The case involves Active Realty and Development Corporation (petitioner) and Bienvenido Fernandez (respondent).
• The dispute concerns a parcel of land covered by Transfer Certificate of Title No. T-85541.
• The petitioner claims to have acquired the land from the Philippine National Bank (PNB) through a Deed of Sale.
• On November 27, 1997, the petitioner filed a complaint for unlawful detainer against the respondent.
• The petitioner alleged that the respondent occupied the land with the previous owner's tolerance and failed to vacate despite a demand letter sent on March 6, 1997.
• The Municipal Trial Court in Cities (MTCC) of Bacolod City ruled in favor of the petitioner on July 27, 1998, ordering the respondent to vacate and pay damages.
• The respondent appealed to the Regional Trial Court (RTC) of Negros Occidental, which reversed the MTCC's ruling on February 3, 2000, citing lack of jurisdiction due to an agrarian dispute.
• The RTC stated that the Department of Agrarian Reform Adjudication Board (DARAB) had primary jurisdiction over agrarian issues as per the Comprehensive Agrarian Reform Law (R.A. No. 6657).
• The Court of Appeals (CA) affirmed the RTC's decision on May 30, 2002.
• The petitioner subsequently filed a petition for certiorari under Rule 65 of the Revised Rules of Court, challenging the CA's ruling and jurisdictional issues.

Issue:

• (Unlock)

Ruling:

• The Supreme Court granted the petition, set aside the CA's decision, and reinstated the MTCC's ruling, affirming the jurisdiction o...(Unlock)

Ratio:

• The Supreme Court determined that the case did not involve an agrarian dispute that would remove jurisdiction from regular courts.
• The Court noted that the respondent did not establish a tenancy relationship, which is necessary to invoke agrarian laws.
• The respondent was not a party to the agrarian case he cited, lacking standing to claim that the DAR had primary jurisdiction.
• The investigation re...continue reading