Title
Rivera vs. Santiago
Case
G.R. No. 146501
Decision Date
Aug 28, 2003
A landowner files a complaint for ejectment against individuals claiming to be tenants, but the court rules that no tenancy relationship exists and upholds the jurisdiction of the Municipal Trial Court over the case.
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Case Digest (G.R. No. 146501)

Facts:

  • The case involves five parcels of land originally owned by Pacifico Santiago, which were inherited by his sons, Jovito and Raymundo Santiago.
  • The Development Bank of the Philippines (DBP) foreclosed the properties due to unpaid loans and sold them to Alejandrina Tuzon.
  • Tuzon initiated legal action against the respondents, who were tilling the land, resulting in a preliminary injunction against them.
  • Flordeliza Rivera purchased the land from Tuzon and subsequently filed an ejectment complaint against Jovito Santiago and others for unlawful occupation.
  • The Municipal Trial Court (MTC) ruled in favor of Rivera, a decision that was upheld by the Regional Trial Court (RTC).
  • The respondents appealed to the Department of Agrarian Relations Adjudication Board (DARAB), which determined that no tenancy relationship existed.
  • The Court of Appeals reversed the decisions of the lower courts, asserting that the case was a tenancy dispute, thus outside the jurisdiction of the MTC.
  • Rivera filed a petition for review with the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Flordeliza Rivera, reversing the decision of the Court of Appeals.
  • The ruling of the RTC was reinstated, affirming that no tenancy relationship...(Unlock)

Ratio:

  • The Supreme Court clarified that asserting agricultural tenancy does not automatically negate the MTC's jurisdiction over ejectment complaints.
  • The essential elements of a tenancy relationship were not adequately established in this case.
  • Jurisdiction is determined by the allegations in the complain...continue reading

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