Title
Bacar vs. People
Case
G.R. No. 226098
Decision Date
Aug 23, 2023
Tenants Bacar and Mercado, declared de jure by DARAB, faced Qualified Theft charges for harvesting copra. SC ruled criminal cases dismissed, affirming DARAB's jurisdiction over agrarian disputes and tenants' rights.
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Case Digest (G.R. No. 226098)

Facts:

Background of the Case
Roberto Bacar and Michael Mercado filed a petition before the Department of Agrarian Reform Adjudication Board (DARAB) against Vicente Tan for the reinstatement of their tenancy status, docketed as DARAB Case Nos. R-0407-0008 to 0010-08.

Criminal Charges
On October 8, 2008, Bacar was charged with Qualified Theft before the Regional Trial Court (RTC) for allegedly stealing two sacks of copra from Tan’s coconut plantation. Mercado was similarly charged with Qualified Theft for allegedly stealing one sack of copra.

DARAB Decision
On December 12, 2011, the DARAB declared Bacar and Mercado as tenants de jure of Tan’s landholdings, entitling them to reinstatement and peaceful possession of the land.

Motion to Quash
Bacar and Mercado filed Motions to Quash the criminal charges, arguing that the RTC lacked jurisdiction since the case involved an agrarian dispute, which falls under the exclusive jurisdiction of the DAR.

RTC and CA Decisions
The RTC denied the Motions to Quash, ruling that the criminal charges did not pertain to an agrarian dispute. The Court of Appeals (CA) upheld the RTC’s decision in Bacar’s case but ordered the referral of Mercado’s case to the DARAB.

Issue:

  1. Whether the RTC has jurisdiction to hear and decide the criminal cases of Qualified Theft filed against Bacar and Mercado, despite the DARAB Decision declaring them as tenants de jure.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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