Title
Arzaga vs. Copias
Case
G.R. No. 152404
Decision Date
Mar 28, 2003
Dispute over Lot No. 5198 ownership; petitioners claim tax sale purchase, respondents assert agrarian rights. SC rules RTC has jurisdiction, remands case.
Font Size:

Case Digest (G.R. No. 152404)

Facts:

1. Ownership and Dispute Over Lot No. 5198:

  • The dispute involves a parcel of land identified as Lot No. 5198, located in Inabasan, San Jose, Antique, measuring approximately 20,521 square meters. The land was declared in the name of Dalmacio Arzaga under Tax Declaration No. 0245.

2. Petitioners' Claim:

  • Petitioners Rodolfo Arzaga and Francis Arzaga claimed to be co-owners of Lot No. 5198, having purchased it in a tax delinquency sale under a Certificate of Sale of Delinquent Real Property dated February 15, 1995.
  • They alleged that private respondents Salvacion Copias and Prudencio Calandria entered and occupied the property without their consent prior to 1994. Despite demands, the respondents refused to vacate, prompting the petitioners to file a complaint for recovery of possession and damages with the Regional Trial Court (RTC) of San Jose, Antique, Branch 11, docketed as Civil Case No. 2859.

3. Respondents' Defense:

  • Private respondents claimed to be amortizing owners of Lot Nos. 5198-A, 5198-B, and 5198-D, which are subdivisions of Lot No. 5198. They asserted that they were tenant-beneficiaries of Caridad Fuentebella, the previous owner of Lot No. 5198.
  • Prudencio Calandria was issued Emancipation Patent No. 500577 and Transfer Certificate of Title (TCT) No. E.P. No. 904 over Lot No. 5198-D (7,808 sqm), and E.P. No. 500575 and TCT No. E.P. No. 902 over Lot No. 5198-B (6,024 sqm). Salvacion Copias, through her husband, was issued E.P. No. 500576 and TCT No. E.P. No. 903 over Lot No. 5198-A (6,367 sqm).
  • They argued that the dispute was an agrarian matter, falling under the jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB), not the RTC.

4. Pre-Trial Stipulations:

  • The parties agreed during pre-trial that:
    • Lot Nos. 5198-A, 5198-B, and 5198-D are parts of Lot No. 5198, all agricultural lands.
    • Prudencio Calandria and Salvacion Copias were issued Emancipation Patents and TCTs over their respective lots.
    • Lot No. 5198 was declared in the name of Dalmacio Arzaga under Tax Declaration No. 0245.
    • A Certificate of Sale of Delinquent Real Property was executed in favor of Rodolfo and Francis Arzaga on February 15, 1995.

5. Trial Court's Decision:

  • The RTC dismissed the case for lack of jurisdiction, ruling that the dispute involved possession and ownership of agricultural lands and the issuance of emancipation patents, which fell under DARAB's jurisdiction.

6. Court of Appeals' Decision:

  • The Court of Appeals affirmed the RTC's dismissal, prompting the petitioners to file the instant petition before the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Jurisdiction of DARAB:

    • Under Rule II, Section 1, paragraph (a) of the Revised Rules of Procedure of the DARAB, the DARAB has primary jurisdiction over agrarian disputes, which include controversies relating to tenurial arrangements over agricultural lands.
    • However, for DARAB to have jurisdiction, there must be a tenancy relationship between the parties. The essential elements of a tenancy relationship are:
      • The parties are the landowner and the tenant or agricultural lessee.
      • The subject matter is agricultural land.
      • There is consent between the parties.
      • The purpose is agricultural production.
      • There is personal cultivation by the tenant or agricultural lessee.
      • The harvest is shared between the landowner and the tenant or agricultural lessee.
  2. Absence of Tenancy Relationship:

    • In this case, the element of a tenancy relationship was absent. The petitioners claimed ownership of Lot No. 5198 based on a Certificate of Sale of Delinquent Real Property, while the respondents asserted ownership over portions of the lot based on Emancipation Patents and TCTs.
    • There was no juridical tie or tenurial relationship between the parties or their predecessors-in-interest. The petitioners' father, Dalmacio Arzaga, had no connection with the respondents or their alleged predecessor-in-interest, Caridad Fuentebella.
  3. Jurisdiction Determined by Complaint Allegations:

    • Jurisdiction over the subject matter is determined by the allegations in the complaint, not by the defenses or theories raised by the defendant.
    • The petitioners' complaint was for recovery of possession (accion publiciana), which falls under the jurisdiction of the RTC. The absence of a tenancy relationship meant the case did not involve an agrarian dispute.
  4. Precedent:

    • The Court cited Chico v. Court of Appeals, where it was held that the absence of a juridical tie between the parties negates the existence of a tenancy relationship, and the regular courts retain jurisdiction over recovery of possession cases.

Conclusion:

The Supreme Court ruled that the RTC has jurisdiction over the case, as the dispute did not involve an agrarian relationship. The case was remanded to the RTC for further proceedings.


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.