Facts:

On May 24, 1994, Antonio P. Abellana (respondent) filed a complaint against Justino Laresma (petitioner) in the Regional Trial Court (RTC) of Toledo, Cebu, Branch 29, seeking recovery of possession of Lot 4-E, a parcel of agricultural land located in Tampa-an, Aloguinsan, Cebu, with an area of 21,223 square meters, covered by Transfer Certificate of Title (TCT) No. 47171. The respondent alleged that the petitioner had been a lessee of Socorro Chiong since 1985 and, through threats and stealth, took possession of his property, depriving him of its use. The respondent sought a judgment ordering the petitioner to vacate the property and pay damages, attorney's fees, and litigation expenses. The complaint included a lease contract executed by the petitioner's wife, Praxedes Seguisabal Laresma, in 1977 over land owned by Socorro Chiong.

The respondent's father, Teotimo Abellana, testified that the petitioner married his maid, Praxedes, and became a tenant of Socorro...

Facts:

Background of the Case

On May 24, 1994, respondent Antonio P. Abellana filed a complaint with the Regional Trial Court (RTC) of Toledo, Cebu, against petitioner Justino Laresma for the recovery of possession of Lot 4-E, a 21,223 square meter agricultural land covered by Transfer Certificate of Title (TCT) No. 47171. Abellana alleged that Laresma, through threats and stealth, unlawfully took possession of the property in 1985.

Respondent’s Claims

Abellana claimed that Laresma was a lessee of Socorro Chiong, whose land adjoined his own. He sought Laresma’s eviction, along with damages, attorney’s fees, and litigation expenses. He presented his father, Teotimo Abellana, as a witness, who testified about Laresma’s alleged encroachment and destruction of coconut trees on the property.

Petitioner’s Defense

Laresma argued that the dispute was agrarian in nature, falling under the exclusive jurisdiction of the Department of Agrarian Reform (DAR). He claimed that his wife, Praxedes Laresma, was issued a Certificate of Land Transfer (CLT) No. 0-031817 over a portion of the property under Operation Land Transfer (OLT) under Presidential Decree No. 27. He asserted that they were the rightful owners and entitled to possession.

Ocular Inspection and Reports

The parties agreed to an ocular inspection to determine whether Lot No. 00013 (covered by CLT No. 0-031817) was part of Lot 4-E (covered by TCT No. 47171). Reports from Municipal Agrarian Reform Technologist Alberto Epan and court process server Felix Navarro were submitted, but the trial court found them insufficient to establish the location of Lot No. 00013.

Trial Court Decision

The RTC ruled in favor of Abellana, declaring him the lawful owner of Lot 4-E and ordering Laresma to vacate the property. The court held that Laresma was not a tenant of Abellana but of Socorro Chiong, and the dispute was civil, not agrarian, in nature.

Issue:

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Ruling:

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Ratio:

1. Jurisdiction Determined by Allegations and Law: The court’s jurisdiction is determined by the material allegations in the complaint and applicable law. The absence of the assessed value in the complaint made it impossible to determine whether the RTC had jurisdiction.
2. No Indirect Attack on CLT: The respondent’s action was for recovery of possession of Lot 4-E, not an indirect attack on the CLT issued to Laresma’s wife.
3. No Agrarian Dispute: The dispute was civil, not agrarian, as there was no tenancy relationship between the parties. Laresma was a tenant of Socorro Chiong, not Abellana.
4. Importance of Technical Descriptions: The court emphasized the need for technical descriptions to establish the exact location of Laresma’s farmholding in relation to Abellana’s property.
5. Nullity of Proceedings: Since the RTC lacked jurisdiction, all proceedings, including its decision, were void.