Case Digest (G.R. No. 201631)
Facts:
Angelina Dayrit, represented by Julie E. Dayrit v. Jose I. Norquillas, et al., G.R. No. 201631, December 07, 2021, Supreme Court En Banc, Hernando, J., writing for the Court. Petitioner Angelina Dayrit owned two parcels in Bolisong, El Salvador, Misamis Oriental (OCT No. P-13388 and TCT No. T-1804). In 1993 portions of these lands were placed under the Comprehensive Agrarian Reform Program (CARP), her original titles were cancelled as to the awarded portions, and Certificates of Land Ownership Award (CLOAs) were issued in favor of various agrarian beneficiaries (respondents or third parties). Angelina filed administrative proceedings before the Department of Agrarian Reform (DAR) seeking exemption from CARP coverage for the parcels and separately moved for annulment of the CLOAs; the annulment petition became DARAB Case No. 13439 and was subsequently archived pending resolution of the exemption application.While the DARAB appeal and the DAR administrative processes were pending, Angelia filed a complaint for forcible entry (Civil Case No. 2006-09-16) against respondents before the 7th Municipal Circuit Trial Court (MCTC) of Opol and El Salvador, alleging that respondents entered the property on September 17, 2006 and refused to vacate. Respondents answered that Angelina had lost ownership and possessory rights over the awarded portions by virtue of the CLOAs and that possession issues were tied to agrarian matters cognizable by DAR/DARAB.
The MCTC, in an April 17, 2007 Decision, found Angelina had prior physical possession and ruled for her, ordering respondents and those under them to vacate; the dispositive portion ordered restoration of possession to Angelina. The Regional Trial Court (RTC), Branch 39, affirmed the MCTC in a December 10, 2008 Decision, emphasizing that forcible entry cases are within the exclusive original jurisdiction of first-level courts under Batas Pambansa Blg. 129 and that possession is distinct from disposition or alienation which DAR handles.
Respondents appealed to the Court of Appeals (CA). In a January 27, 2012 Decision, the CA reversed and dismissed the complaint for lack of jurisdiction, holding that the case is linked to an agrarian dispute because respondents occupied the parcels by virtue of CLOAs and that the DARAB has primary jurisdiction over agrarian disputes; the CA also invoked litis pendentia because of pending DAR proceedings. The CA denied Angelina’s motion for reconsideration in a March 28, 2012 Resolution.
Angelina petitioned the Supreme Court by petition for review on certiorari (consolidated initially with G.R. No. 201076 but later deconsolidated); she argued that the forcible entry action concerns mere possession and therefore falls under the courts’ jurisdi...(Pro-only)
Issues:
- Does the Municipal Circuit Trial Court have jurisdiction over the complaint for forcible entry in the circumstances of this ca...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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