Title
Machete vs. Court of Appeals
Case
G.R. No. 109093
Decision Date
Nov 20, 1995
A dispute over unpaid agricultural leasehold rentals was dismissed by the RTC, deemed an agrarian issue under DAR jurisdiction, later upheld by the Supreme Court.

Case Digest (G.R. No. 109093)

Facts:

Lope Machete, Nicasio Jumawid, et al. v. Court of Appeals and Celestino Villalon, G.R. No. 109093, November 20, 1995, First Division, Bellosillo, J., writing for the Court.

On 21 July 1989 private respondent Celestino Villalon filed a complaint for collection of back rentals and damages in the Regional Trial Court (RTC) of Tagbilaran City against petitioners Lope Machete, Nicasio Jumawid, Santiago Jumawid, John Jumawid, Pedro Gamaya, Renato Delgado, Fernando Ombahin, Matias Roleda, Pasiano Baro, Ignacio Baro, Mamerto Plaras and Justiniano Villalon. The complaint alleged that the parties had entered into a leasehold agreement concerning respondent’s lands in Poblacion Norte, Carmen, Bohol, under which the tenants were to pay a specified amount or a percentage of their harvests; respondent alleged repeated nonpayment and demanded back rentals and damages.

Petitioners moved to dismiss for lack of subject-matter jurisdiction, arguing that the controversy was agrarian in nature and therefore fell within the exclusive original jurisdiction of the Department of Agrarian Reform (DAR) and its adjudicatory body, the DAR Adjudication Board (DARAB), under the DARAB Revised Rules (Sec. 1, pars. (a) and (b), Rule II). On 22 August 1989 the RTC granted the motion to dismiss, and on 28 September 1989 denied petitioners’ motion for reconsideration.

Private respondent appealed to the Court of Appeals, which on 21 May 1992 reversed the RTC and directed it to assume jurisdiction, concluding that the case constituted a simple collection action not requiring in...(Pro-only)

Issues:

  • Did the Regional Trial Court have jurisdiction to entertain a complaint for collection of back rentals arising from a leasehold agreement over agricultural land, or was the dispute exclusively within the DAR/DARAB's original jurisdiction?
  • Did the Court of Appeals commit error in reversing the RTC's dismissal and directing the R...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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