Case Summary (G.R. No. 184971)
Procedural History and Jurisdictional Dispute
In 2013, the petitioner filed a Complaint for Quieting of Title, Accion Reivindicatoria, and Damages at the Regional Trial Court (RTC) of BiAAn, Laguna, seeking to remove the respondents, whom he claims to be trespassers clouding his title. The respondents filed a motion to dismiss on the ground that the RTC lacked jurisdiction, asserting the case involves an agrarian dispute which falls under the exclusive jurisdiction of the DARAB. The RTC denied the motion to dismiss, asserting jurisdiction based on the allegations in the complaint and the assessed value of the property. The respondents elevated the matter to the Court of Appeals (CA) via a Petition for Certiorari, which annulled the RTC’s interlocutory orders for lack of jurisdiction, holding that the DARAB has jurisdiction over agrarian disputes and emphasizing the respondents’ recognized tenant status.
Nature of the Case and Jurisdictional Issue
The central legal question is whether the RTC has jurisdiction over a complaint that seeks to quiet title and oust purported tenants based on claims adverse to prior agrarian decisions. Jurisdiction is determined by the allegations in the complaint, not by defenses. The petitioner argues the absence of a tenancy relationship with the respondents and stresses that the defendants were not tenants of the petitioner or his predecessors, nor were the petitioner or co-owners parties to the prior agrarian cases involving the Erana family. Therefore, the petitioner contends that the PARAD and DARAB decisions constitute clouds on his title, justifying quieting of title in regular courts.
Jurisdiction of Regular Courts and DARAB
Jurisdiction over actions for quieting of title lies with regular courts, as such actions are governed under Articles 476 and 477 of the Civil Code, aimed at removing or preventing invalid clouds on title. By contrast, DARAB’s jurisdiction is confined to agrarian disputes involving tenancy relationships. An agrarian dispute presupposes the existence of a tenancy relationship between the landowner and agricultural tenants concerning land devoted to agriculture. The courts emphasized that there must be proof of a valid landlord-tenant relationship, including consent, the agricultural nature of the land, and sharing of harvests, before DARAB’s jurisdiction attaches.
Absence of Tenancy Relationship
The Court found no evidence of a tenancy relationship between petitioner/co-owners and respondents. The Municipal Agrarian Reform Office (MARO) issued a certification showing no tenancy record over the subject land under the petitioner’s grandfather. Respondents themselves admitted ignorance of the petitioner or his co-owners and stated that they paid shares to the Eranas and later to unrelated parties, none of whom were predecessors or duly connected to the petitioner. These facts negate the critical element of consent and landlord-tenant relationship, which are fundamental for DARAB jurisdiction.
Effect on Security of Tenure Rights
Respondents rely on Sections 7 and 10 of Republic Act No. 3844 (Agricultural Land Reform Code), which grant tenants security of tenure and provide that tenancy rights survive transfer of ownership. However, this protection applies only if the transferee is a successor in interest to the landlord in the tenancy relationship. Since the petitioner is unrelated and not a successor to the respondents’ landlord, the Court held these provisions cannot be invoked against him. Precedents confirm that absent a de jure tenancy, one is not entitled to security of tenure or protection under agrarian laws.
Interlocutory Nature of RTC Orders and Proper Remedy
The RTC’s denial of the respondents’ motion to dismiss constitutes an interlocutory order, which is generally not appealable. The proper recourse is to answer the complaint and raise defenses during trial, with appeal available only after final judgment. Nevertheless, interlocutory orders may be subject to certiorari only upon showing of grave abuse of discretion amounting to lack or excess of jurisdiction. The Court found no such grave abuse in the RTC’s orders, as the RTC correctly exercised jurisdiction over the quieting of title action based on the complaint’s allegations.
Prevailing Doctrine on DARAB Decisions as Clouds on Title
The Court referred to prior rulings, notably Green Acres Holdings, Inc. v. Cabral, which recognized that a DARAB decision may be treated as an “inst
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