Case Summary (G.R. No. 226358)
Petitioner and Respondent
- Petitioners: Roberto Bacar and Vicente Tan
- Respondents: People of the Philippines and Michael Mercado
Key Dates
- Petitions for Certiorari filed on various dates leading to decisions rendered on August 23, 2023.
Applicable Law
The principal statute in question is Republic Act (R.A.) No. 6657, as amended by R.A. No. 9700, which outlines the jurisdiction over agrarian disputes. The Revised Penal Code, particularly Article 310 regarding Qualified Theft, also plays a critical role in these cases.
Antecedents for G.R. No. 226098
On August 7, 2008, Bacar and co-petitioner Michael Mercado petitioned the Department of Agrarian Reform Adjudication Board (DARAB) against Vicente Tan, which recognized Bacar and Mercado as de jure tenants. However, in October 2008, Bacar faced charges of Qualified Theft for allegedly stealing copra belonging to Tan.
Motion to Quash
Bacar filed a Motion to Quash the charges based on the argument that the case involved an agrarian dispute and should fall under the DAR's jurisdiction, but the Regional Trial Court (RTC) dismissed this motion. The RTC asserted its jurisdiction, holding that the charge did not pertain to agrarian reform.
Court of Appeals Ruling
On February 4, 2016, the Court of Appeals upheld the RTC's denial of Bacar's motions, asserting that Qualified Theft, as charged, was a criminal matter within the RTC's jurisdiction and did not involve an agrarian dispute. Bacar then sought further relief through the Supreme Court.
Antecedents for G.R. No. 233817
Simultaneously, Mercado faced similar charges of Qualified Theft regarding a separate occurrence involving copra. He also filed a Motion to Quash on the same grounds, asserting the agrarian nature of the claim based on the DARAB's ruling. The RTC ruled against Mercado, confirming its jurisdiction remains intact over theft claims.
Court of Appeals Ruling
On January 20, 2017, the Court of Appeals granted Mercado’s petition, determining that the case represented an agrarian dispute and directing the RTC to refer the matter to the DARAB. The Court emphasized the need to ensure that agrarian disputes were resolved by the proper administrative bodies per the established statutory framework.
Core Issue
The fundamental issue across both petitions revolves around the jurisdiction of the RTC in hearing the Qualified Theft cases, given the prior adjudications by the DARAB declaring both Bacar and Mercado as tenants de jure, which raise the question of whether the cases involve agrarian disputes.
The Court's Ruling
The Court found that the grounds for determining agrarian disputes were met as both petitioners were recognized as de jure tenants. The Court emphasized that allegations of agrarian nature and recognition as tenants by the DARAB warranted automatic referral to the DAR. It underscored the implication of such a designation on the criminal liability concerning theft charges.
Consequence
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Background of the Case
- The case involves two petitions for review on certiorari, with Roberto Bacar (G.R. No. 226098) and Vicente Tan (G.R. No. 233817) as petitioners challenging the decisions of the Court of Appeals (CA).
- Bacar's petition challenges the CA's affirmation of the Regional Trial Court (RTC) of Puerto Princesa City's orders denying his motion to quash an information for Qualified Theft.
- Tan's petition disputes the CA's directive to refer a separate Qualified Theft case involving Michael Mercado to the Department of Agrarian Reform Adjudication Board (DARAB), asserting that the RTC should retain jurisdiction.
Key Facts of G.R. No. 226098
- On August 7, 2008, Bacar and his brother-in-law filed a petition with DARAB against Tan for reinstatement of their tenancy status, leading to a determination that they were tenants de jure of Tan's landholdings.
- Bacar was charged with Qualified Theft for allegedly stealing two sacks of copra valued at PhP1,400 from Tan's plantation on February 24, 2008.
- After being arraigned and pleading not guilty, Bacar filed a motion to quash the information based on the argument that the RTC lacked jurisdiction over what he claimed was an agrarian dispute.
RTC and CA Proceedings
- The RTC denied Bacar's motion to quash on November 29, 2012, asserting its jurisdiction as the case did not pertain to the implementation of th