Case Summary (G.R. No. 226098)

Overview of the Case

The Supreme Court reviewed two petitions for certiorari involving Roberto Bacar and Vicente Tan concerning criminal charges of Qualified Theft. Bacar and Mercado, both tenants de jure as declared by the Department of Agrarian Reform Adjudication Board (DARAB), contested the jurisdiction of the Regional Trial Court (RTC) over their criminal cases, arguing that the disputes were agrarian in nature.

Antecedents of G.R. No. 226098

• Background: Bacar was charged with Qualified Theft for allegedly stealing copra from Tan's plantation. Bacar claimed jurisdiction belonged to the DAR because he was a recognized tenant.
• Court Rulings: The RTC denied Bacar's motion to quash the information, asserting it had jurisdiction. This was affirmed by the Court of Appeals (CA).
• Key Dates:
  • Charges filed: October 8, 2008
  • Bacar's arraignment: January 22, 2009
  • RTC's Order denying motion: November 29, 2012
  • CA's Decision affirming RTC: February 4, 2016

Antecedents of G.R. No. 233817

• Background: Mercado, similarly charged with Qualified Theft, also filed a motion to quash based on the agrarian dispute argument.
• Court Rulings: The RTC denied his motion; however, the CA later granted Mercado's petition, ordering the RTC to refer the case to the DARAB.
• Key Dates:
  • Charges filed against Mercado: February 25, 2008
  • CA's Decision granting Mercado's petition: January 20, 2017

Legal Provisions on Jurisdiction

Section 50-A of R.A. No. 6657

• Legal Principle: Establishes exclusive jurisdiction over agrarian disputes to the DAR.

• Key Definitions:

  • Agrarian Dispute: Any controversy relating to tenancy, land ownership, and other agrarian reform issues.

• Requirements for Referral:

  • An allegation that the case is agrarian in nature.
  • One party must be a farmer, farmworker, or tenant.

• Procedures:

  • Judges/prosecutors must automatically refer cases to the DAR if the above conditions are met.
  • The DAR must determine and certify within 15 days if an agrarian dispute exists.

• Consequences:

  • Failure to comply with referral requirements can result in jurisdictional errors.

Supreme Court Rulings

• Findings: The DARAB's recognition of Bacar and Mercado as tenants de jure established a prima facie agrarian dispute, necessitating referral to the DAR.
• Outcome: The Court dismissed the criminal cases against Bacar and Mercado, recognizing their rights as tenants.
• Implications for Future Cases:
  • The necessity for strict adherence to the referral procedures established by agrarian laws.
  • Acknowledgment of the DARAB's authority in determining tenancy status and agrarian rights.

Key Takeaways

• The Supreme Court affirmed the jurisdiction of the DAR over agrarian disputes, emphasizing the importance of the tenant status in criminal cases involving Qualified Theft.
• Both Bacar and Mercado were acquitted of charges due to their recognized rights as tenants, demonstrating the interplay between criminal law and agra...continue reading

Case Syllabus (G.R. No. 226098)

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 ...continue reading