G.R. No. 127965 - Salazar vs. De Leon

The case originated when respondent Reynaldo de Leon, through his attorney-in-fact Feliciano Jabonilla, filed a Complaint in Civil Case No. 419 before the RTC of Roxas, Isabela, seeking recovery of possession and damages for a disputed parcel of land.
The RTC, acting on petitioner's default (owing to his failure to file an Answer), granted respondent’s relief by ordering petitioner Francisco Salazar to vacate and surrender peaceful possession of the property, and to pay damages and attorney’s fees.
Petitioner moved for a New Trial and the lifting of the Order of Default, arguing that he had entrusted his case to his counsel and stressing that the dispute involved a tenancy relationship over which the RTC allegedly lacked jurisdiction. His motion was denied on merit.
An appeal was subsequently filed with the Court of Appeals (CA-G.R. CV No. 46108), where petitioner contended that the underlying relationship was one of landlord and tenant, hence falling under the exclusive jurisdiction of the Department of Agrarian Reform (DAR).

The subject property is a 2-hectare parcel of unirrigated rice land situated in Barrio MuAoz, Roxas, Isabela, covered by TCT No. T-85610.
Although petitioner was not a tenant in the conventional sense, he was allowed by respondent—his close relative—to cultivate the land without rental, under the understanding that he would eventually surrender possession when demanded by respondent.
A further dispute arose when respondent demanded the property for his personal cultivation, and petitioner, claiming a potential claim under the Operation Land Transfer Program of DAR, refused to vacate.
Meanwhile, petitioner had initiated proceedings before the DAR Adjudication Board (DARAB) in DARAB Case # II-380-ISA’94, wherein a decision later affirmed his status as a bona fide tenant of respondent.

The DARAB decision, dated 17 November 1995, relied on documentary evidence including receipts of rental payments, barangay and ARBA certifications, and even the TCT as evidence of tenure, conclusively finding petitioner to be the tenant.
This administrative decision became pivotal as it established not only the tenancy relationship but also the inherent agrarian nature of the dispute.
Both parties later entered into an Agricultural Leasehold Contract confirming the tenancy relationship, and subsequent attempts to settle the case extrajudicially led to motions to withdraw by the counsels, though no formal settlement document was completed or approved by the Court.

The Court of Appeals, in its decision dated 8 August 1996, affirmed the RTC’s ruling on the basis that the facts alleged in the complaint showed possession issues notwithstanding claims of tenancy.
Petitioner’s Motion for Reconsideration was likewise denied on 8 January 1997, prompting the filing of the present Petition for Review on Certiorari before the Supreme Court.
The Supreme Court eventually determined that the dispute is agrarian in nature, emphasizing the exclusive jurisdiction of the DARAB over such matters and ruled accordingly on the issue of jurisdiction.

Whether the trial court (RTC) had proper jurisdiction over the dispute which allegedly involved a tenancy/agricultural dispute.
Whether the dispute, characterized by the relationship between petitioner and respondent, falls within the exclusive agrarian jurisdiction of the DARAB.

Whether petitioner Francisco Salazar is to be construed as a bona fide tenant of respondent Reynaldo de Leon.
Whether the evidentiary record, including documented rental receipts and certifications, sufficiently supports the existence of a tenancy relationship.

Whether the DARAB decision, having attained finality, binds the courts as res judicata concerning the determination of the tenancy relationship.

Whether petitioner’s relief based on the claim that the dispute is agrarian in character and should thus be decided by the DARAB should be granted.
Whether the decisions of the RTC and the Court of Appeals, which were based on possession issues rather than tenancy, should be reversed or set aside.