G.R. No. 83614 - Alonto, Jr. vs. Memoracion

Petitioners, Jaime Morta, Sr. and Purificacion Padilla, filed two separate cases for damages with preliminary injunction on January 10 and 21, 1994, before the Municipal Trial Court, Guinobatan, Albay.
The cases were consolidated pursuant to Rule 31 of the Revised Rules of Court, and involved claims against respondents Jaime Occidental, Atty. Mariano Baranda, Jr., and Daniel Corral for alleged wrongful acts.

Petitioners alleged that respondents, through the instigation of Atty. Baranda, gathered pilinuts, anahaw leaves, and coconuts from their land.
The complaints further claimed that respondents delivered the gathered produce to Atty. Mariano Baranda, Jr. and destroyed the petitioners’ banana and pineapple plantations.
Specific monetary claims were made: Civil Case No. 481 sought damages of P8,930.00 (later reduced to P8,130.00 for the value of the produce and damaged plants plus reimbursement of legal expenses of P202.00), and Civil Case No. 482 sought P9,950.00 alongside similar legal expenses.

The Municipal Trial Court ordered respondents to file their answer; respondents contested the petitioners’ ownership of the land, alleging that the Torrens titles indicated Gil Opiana as the registered owner, with Josefina Opiana-Baraclan as the heir.
Respondent Jaime Occidental claimed he was a bona fide tenant of Josefina Opiana-Baraclan and denied the alleged harvesting and delivery of produce, as well as the destruction of the petitioners’ plantations.
On March 29, 1994, the Municipal Trial Court rendered a decision in favor of the petitioners, holding that they had possessed the land for 45 years in an actual, continuous, open, and adverse manner.
The decision included specific orders: restraining the defendants from disturbing the petitioners’ possession, awarding damages for the loss of produce and destroyed plantations, and reimbursement of legal expenses.

Respondents appealed the decision to the Regional Trial Court, Ligao, Albay, arguing that the case fell within the original and exclusive jurisdiction of the Department of Agrarian Reform Adjudicatory Board (DARAB) since it involved tenancy-related issues.
The RTC reversed the Municipal Trial Court’s decision on August 10, 1994, dismissing the cases on the ground that the dispute was tenancy-related, and pointed out that the filing of these actions concurrently with a related case before the DARAB amounted to forum shopping.
Petitioners then filed a petition for review with the Court of Appeals, which on May 31, 1995, affirmed the RTC’s ruling on jurisdiction but ruled that forum shopping did not occur.
Subsequent motions for reconsideration and a supplemental motion were filed by petitioners, with arguments supported by certification from the Municipal Agrarian Reform Office (MARO) that Morta was not a tenant. These motions were denied on December 8, 1995.

An essential dispute emerged regarding the ownership of the land, with petitioners asserting their long-standing possession and respondents contending, based on title records, that another party (Josefina Opiana-Baraclan) was the rightful owner.
This conflict raised the question whether the case was truly tenancy-related or rather an action for damages based on ownership and possession.

The Supreme Court granted the petition for review on certiorari, focusing on the nature of the allegations contained in the petitioners’ complaint.
It emphasized that jurisdiction must be determined from the complaint’s pleadings and the relief sought, and that the issues raised did not satisfy the requisites for a tenancy relationship.
As a result, the Supreme Court set aside the decisions of both the Court of Appeals and the Regional Trial Court, and affirmed the decision of the Municipal Trial Court in favor of the petitioners.

Whether the cases for damages filed by petitioners are tenancy-related actions and thus fall within the exclusive jurisdiction of the DARAB, or whether they are properly within the jurisdiction of the municipal trial court as actions for damages.
Whether the allegations in the complaint, which focus on unauthorized harvesting and destruction of plantations, create a tenancy relationship requiring adjudication by the DARAB.

The dispute over the rightful ownership of the land—whether the petitioners or Josefina Opiana-Baraclan is the true owner—implicates the determination of tenancy since tenancy requires a clear landowner-tenant relationship.
Whether any uncertainty regarding the ownership of the land precludes the establishment of a tenancy relationship, thereby affecting the proper forum for the case.

Whether jurisdiction should be determined solely on the basis of the pleadings in the complaint and the nature of the relief sought, despite later defenses or claims raised by the respondents.
Whether the claim that petitioners engaged in forum shopping affects the determination of proper jurisdiction.