G.R. No. 227529 - Almazan vs. Bacolod

Petitioner, Eduviges B. Almazan, together with his co-owners, inherited a 5,865 square meter parcel of agricultural land located in Barangay Dita/Malitlit, Sta. Rosa City, Laguna, covered by Transfer Certificate of Title No. T-060-2012008993 from their grandfather Agapito Almazan.
In 2010, petitioner discovered respondents Perla E. Bacolod, Dulce E. Bacolod, Irma E. Bacolod, and Belen E. Bacolod occupying the land. Petitioner demanded their eviction, which the respondents refused, asserting tenancy rights.

Respondents claimed to be agricultural tenants of the land under prior final decisions by the Provincial Agrarian Reform Adjudicator (PARAD) dated July 3, 2000, and the Department of Agrarian Reform Adjudication Board (DARAB) dated October 11, 2007.
Petitioner denied any tenancy relation with respondents or their predecessors, maintaining that the agrarian rulings applied only to the Erana family (Arturo, Norberto, Virginia, Ruben, Manuel, Bayani), who are unrelated and distinct from petitioner and co-owners.

On February 7, 2013, petitioner filed before the Regional Trial Court (RTC) of Biñan, Laguna, a Complaint for Quieting of Title, Accion Reivindicatoria (recovery of possession), and Damages against respondents to remove what he considered clouds on his title.
Respondents filed a Motion to Dismiss citing lack of RTC jurisdiction, arguing that the matter involves agrarian disputes under DARAB’s exclusive jurisdiction, and that they are lawful tenants entitled to security of tenure.
TheRTC denied the motion to dismiss in its April 14, 2014 Order and reaffirmed this denial in the July 7, 2014 Order, holding that jurisdiction is determined by the allegations in the complaint.

Respondents elevated their challenge to the CA via a Petition for Certiorari under Rule 65, assailing the RTC orders.
The CA, in its March 7, 2016 Decision, annulled and set aside the RTC orders, ruling that jurisdiction properly belonged to the DARAB since the disputes pertain to tenancy and agrarian relations.
The CA acknowledged the interlocutory nature of RTC’s orders but allowed certiorari as remedy due to alleged grave abuse of discretion.
The CA’s Resolution dated September 30, 2016 denied petitioner’s motion for reconsideration.

Petitioner filed the instant Petition for Review on Certiorari before the Supreme Court, asserting:

The RTC has jurisdiction over the quieting of title since the respondents have no tenancy relationship with petitioner or his predecessors.
The DARAB decisions are inapplicable and constitute clouds on petitioner’s title.
The petition primarily raises a question of law regarding jurisdiction, which is within the scope of Rule 45.
The CA erred in applying the doctrine on subrogation of tenancy rights to petitioner given the absence of any link to respondents or their prior landlords.
The alleged tenancy relationship cannot be presumed or enforced against strangers to the prior tenurial arrangements.

Respondents maintained they are lawful, de jure tenants as affirmed by final PARAD and DARAB decisions, thus enjoying security of tenure, and that the RTC lacked jurisdiction to nullify these adjudications or eject them. They alleged harassment and deceitful tactics by the petitioner’s counsel.

Whether the Regional Trial Court (RTC) has jurisdiction over the Complaint for Quieting of Title, Accion Reivindicatoria, and Damages filed by petitioner against respondents.

Whether the Department of Agrarian Reform Adjudication Board (DARAB) has exclusive jurisdiction over the case based on the alleged tenancy relationship between the parties.

Whether the prior PARAD and DARAB decisions constitute clouds on petitioner’s title and consequently whether petitioner may seek relief via quieting of title action before the RTC.

Proper legal remedy for challenging interlocutory orders denying a motion to dismiss for alleged lack of jurisdiction.