Case Digest (G.R. No. 169691)
Facts:
Pedrito Salmorin v. Dr. Pedro Zaldivar, G.R. No. 169691, July 23, 2008, Supreme Court First Division, Corona, J., writing for the Court.Petitioner Pedrito Salmorin was designated administrator of Lot No. 7481‑H (15.4360 hectares) in Mapatag, Hamtic, Antique, under a July 15, 1989 agreement (a "kasugtanan") with respondent Dr. Pedro Zaldivar, who possessed the lot as representative of his wife, an heir. The kasugtanan provided Salmorin a monthly salary of P150. Zaldivar later terminated Salmorin’s services, alleging Salmorin failed to till vacant areas, and demanded possession; Salmorin refused to vacate.
Zaldivar filed an unlawful detainer complaint in the Municipal Circuit Trial Court (MCTC) of Tobias Fornier‑Anini‑y‑Hamtic, docketed Civil Case No. 229‑H. Salmorin answered asserting a tenancy relationship, contending the dispute was agrarian in nature and thus beyond the MCTC’s jurisdiction. After examining position papers, the MCTC dismissed the complaint for lack of jurisdiction, treating the matter as agrarian.
Zaldivar appealed to the Regional Trial Court (RTC) of San Jose, Antique. The RTC ruled for Zaldivar, finding the requisites of agricultural tenancy—notably the landowner’s consent and sharing of harvest—were absent, and ordered Civil Case No. 229‑H reinstated in the MCTC. Salmorin appealed to the Court of Appeals (CA), which, in a January 31, 2005 decision and a September 8, 2005 resolution of the Twentieth Division (per Justice Sesinando E. Villon), affirmed the RTC. Salmorin then filed this petition for review on certiorari under Rule 45 of ...(Subscriber-Only)
Issues:
- Did the regular courts have jurisdiction over Civil Case No. 229‑H despite petitioner’s assertion of an agrarian tenancy?
- Did respondent Zaldivar have the right to possess Lot No...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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