Title
Almazan vs. Bacolod
Case
G.R. No. 227529
Decision Date
Jun 16, 2021
Petitioner seeks to quiet title and recover land from respondents claiming tenancy; SC rules RTC has jurisdiction, no tenancy proven.
land ownership dispute
legal battle
registered owner
A

Case Summary (G.R. No. 227529)

Central legal issue

Whether the RTC has jurisdiction over the action for quieting of title, accion reivindicatoria, and damages, or whether jurisdiction lies exclusively with the DARAB because the controversy implicates agrarian tenancy and security of tenure.

Governing standards on jurisdiction and proper remedy

  • Jurisdiction over subject matter is determined by the allegations in the complaint and by the character of the relief sought. Once a court acquires jurisdiction, it generally does not lose it by defenses raised in answers or motions to dismiss.
  • A petition for review under Rule 45 is limited to questions of law; the issue of a tribunal’s jurisdiction is a question of law suitable for Rule 45 review.
  • An interlocutory order (e.g., denial of motion to dismiss) is ordinarily not appealable; certiorari under Rule 65 to assail an interlocutory order is available only upon a showing of grave abuse of discretion amounting to lack or excess of jurisdiction.

Nature and requisites of an action to quiet title

  • Articles 476 and 477 of the Civil Code provide the statutory remedy to remove a cloud on title: the plaintiff must show legal or equitable title or interest in the property and that the instrument, record, claim, encumbrance, or proceeding casting the cloud, though apparently valid, is in truth invalid, ineffective, voidable, or unenforceable and prejudicial to the plaintiff’s title.
  • A DARAB decision may constitute an “instrument,” “record,” “claim,” or “proceeding” that can be alleged to be a cloud on title (as recognized in Green Acres Holdings, Inc. v. Cabral).

Scope of DARAB jurisdiction and the essentiality of a tenancy relationship

  • Section 50 of R.A. No. 6657 vests the DAR with primary, exclusive original jurisdiction over agrarian reform matters; an “agrarian dispute” concerns controversies relating to tenurial arrangements involving agricultural lands.
  • A necessary prerequisite for DARAB jurisdiction is the existence of an agricultural tenancy relationship between the parties. Such tenancy cannot be presumed; it must be proven by showing the six conventional elements: (i) that the parties are owner and tenant or agricultural lessee; (ii) the land is agricultural; (iii) consent to the relationship; (iv) purpose is agricultural production; (v) the tenant personally cultivates the land; and (vi) there is sharing of the harvest.

Application of the legal requisites to the pleaded facts

  • The RTC complaint alleges petitioner’s registered title, inheritance from Agapito, MARO certification indicating Agapito had no registered tenants, petitioner’s lack of relation with Erana, respondents’ admissions that they do not know petitioner or his co‑owners, and that respondents had paid share to Erana and later to other persons (not petitioner or his predecessors).
  • Applying the six requisites, the Supreme Court found no landlord‑tenant relationship between petitioner and respondents: there is no showing that petitioner (or his predecessors) had consented to or occupied the requisite position vis‑à‑vis respondents; MARO’s certification, coupled with respondents’ own allegations that they paid harvest shares to Erana and later to others, supports the absence of tenancy vis‑à‑vis petitioner and his co‑owners. Consequently, the DARAB’s exclusive jurisdiction over agrarian disputes was not triggered in respect of petitioner’s claim.

Limitations on applying RA 3844 Section 10 (security of tenure to transferee)

  • Sections 7 and 10 of RA No. 3844 protect tenants’ security of tenure and provide that tenancy survives sale or transfer, with the purchaser subrogated to the rights and obligations of the prior lessor. However, Section 10 applies to transferees who are successors or privies of the landlord.
  • The CA relied on Section 10 to hold that petitioner, as a landowner, was subrogated to the rights of the respondents’ lessor. The Supreme Court rejected that application because petitioner was not shown to be a transferee or successor of the respondents’ landlord; there was no link proving petitioner’s predecessor was the same person or entity against whom the PARAD/DARAB decisions were rendered. Absent this link, security‑of‑tenure protection cannot be invoked against a stranger to the tenancy relationship.

Jurisdictional conclusion and limitations of the review

  • The Supreme Court concluded that the RTC had jurisdiction over the complaint for quieting of title and related reliefs because the complaint, by its allegations, presented an action cognizable under Articles 476–477 of the Civil Code and sought to remove an asserted cloud on petitioner’s registered title. The absence of a proven tenancy relationship between petitioner (or his predecessors) and respondents meant the controversy was not prima facie an agrarian dispute falling under DARAB’s exclusive original jurisdiction.
  • The Court’s ruling on jurisdiction was confined to that legal question and did not pre

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