G.R. No. 201631 - Dayrit vs. Norquillas

Angelina Dayrit was the registered owner of two parcels of land in Bolisong, El Salvador, Misamis Oriental.
In 1993, the lands were placed under the Comprehensive Agrarian Reform Program (CARP), which led to the cancellation of her original titles and the issuance of Certificates of Land Ownership Award (CLOA) in favor of the respondents.

A petition for annulment of the CLOAs before the Department of Agrarian Reform Adjudication Board (DARAB).
An application for exemption from CARP coverage for the subject parcels with the Department of Agrarian Reform (DAR).
A complaint for forcible entry alleging that on September 17, 2006, respondents surreptitiously entered her property and refused to vacate.

The forcible entry case was filed before the Municipal Circuit Trial Court (MCTC) of Opol and El Salvador.

The MCTC ruled in favor of petitioner, holding that evidence of prior physical possession was sufficient even though the dispute involved land transferred under CARP.
The Regional Trial Court (RTC) affirmed the MCTC’s decision.
On appeal, the Court of Appeals (CA) reversed the lower court rulings and dismissed the forcible entry complaint, determining that the issue of possession was inextricably linked to an agrarian dispute.
Initially, the cases in G.R. Nos. 201076 (petitioner’s annulment and exemption case) and 201631 (forcible entry complaint) were consolidated to avoid conflicting decisions; however, the Supreme Court later deconsolidated G.R. No. 201076 from G.R. No. 201631.

Petitioner maintained that a forcible entry action is essentially a remedy for the recovery of physical possession and should fall within the jurisdiction of the lower courts.
Respondents argued that since the land involved was subject to CARP and the transfer of possession was effected through the issuance of CLOAs, the dispute is agrarian in nature.
The respondents’ consistent allegations—and recognition of their status as agrarian reform beneficiaries—were key to framing the dispute as an agrarian matter.

Whether the Municipal Circuit Trial Court had jurisdiction over the forcible entry complaint given that:

The core issue is the recovery of physical possession (a summary ejectment action).
Alternatively, the dispute is intertwined with agrarian reform matters as evidenced by the issuance of CLOAs and the attendant agrarian dispute.

Whether the mandatory referral mechanism under Republic Act No. 9700, which automatically refers any case alleging agrarian dispute involving a farmer, farmworker, or tenant to the Department of Agrarian Reform, applies to this forcible entry case.