G.R. No. 9069 - Municipality of Cavite vs. Rojas

Wilson Jesena originally owned four parcels of land in New Lucena, Iloilo.
On June 20, 1970, Wilson entered into an agreement with Jorge Sombilla, designating Jorge as his agent to oversee the tilling and farming of his riceland for crop year 1970-1971.

Prior to the expiration of the original agreement, on August 20, 1971, Wilson sold the four parcels of land to Timoteo Jusayan.
Following the sale, Timoteo and Jorge entered into a verbal agreement wherein Jorge would retain possession of the land and, in return, deliver 110 cavans of palay annually to Timoteo, with Jorge assuming the responsibility of paying the irrigation fees.
The agreement did not require an accounting of the cultivation expenses, effectively limiting Timoteo’s control over the farming operations.

The verbal arrangement was consistently followed from 1971 to 1983.
In 1975, the land was transferred to Timoteo’s sons (Manuel, Alfredo, and Michael), who later became the petitioners.
In 1984, Timoteo sent several letters to Jorge, terminating his administrative role and demanding the return of possession of the leased parcels.
Due to Jorge’s failure to render an accounting and to surrender possession despite repeated demands, Timoteo filed a complaint for recovery of possession and accounting on June 30, 1986 before the RTC (CAR Case No. 17117).

After Timoteo’s death on October 4, 1991, the petitioners substituted him as plaintiffs in the ongoing case.
The Regional Trial Court (RTC), Branch 30, Iloilo City, rendered a decision on April 13, 1999, upholding the contractual relationship of agency between Timoteo and Jorge and ordering the return of possession to the petitioners.
Jorge, in his answer, asserted that he enjoyed security of tenure as an agricultural lessee, claiming he could not be dispossessed without valid cause.

On October 20, 2003, the CA reversed the RTC’s decision, characterizing the relationship between the parties as one of agricultural tenancy.
The CA held that since Timoteo’s demand involved the delivery of harvest and payment of irrigation fees, it amounted to an agrarian dispute within the exclusive jurisdiction of the Department of Agriculture pursuant to Republic Act No. 6657.

The core factual issue revolves around whether the relationship between the parties is best characterized as an agency (with Timoteo as principal and Jorge as agent) or as a tenancy (whether as a civil law lease or an agricultural lease).
A consequential effect is the question of whether the RTC had original exclusive jurisdiction over the dispute when the complaint was filed in 1986.

Whether the contractual relationship between Timoteo and Jorge was one of agency or an agricultural leasehold tenancy?
Whether the evidentiary features of the agreement point to representation (agency) or to a leasing arrangement for agricultural purposes?

Whether the Regional Trial Court (RTC), Branch 30, Iloilo City had original exclusive jurisdiction over the case at the time the complaint was filed in 1986?
Whether the subsequent reclassification of the dispute as agrarian (and thus falling under the jurisdiction of the Department of Agriculture or the Courts of Agrarian Relations) is legally sustainable given the statutory framework in force at the onset of the action?