Title
David vs. Rivera
Case
G.R. No. 139913
Decision Date
Jan 16, 2004
Dispute over 18,000 sqm land in Pampanga; conflicting claims of ownership vs. tenancy, jurisdiction issues between MCTC and PARAB, resolved by SC affirming RTC's denial of dismissal.
agrarian dispute
ownership of subject land
disturbance compensation
A

Case Summary (G.R. No. 139913)

Factual Background

Respondent alleged that petitioners had harassed him to compel him to vacate the subject land despite his peaceful possession. He traced his right to possession to a 1957 conveyance as disturbance compensation, predicated on his renunciation of tenurial rights over the original eighteen (18)-hectare farmholding given by petitioners’ parents.

Petitioners disputed the asserted agrarian tenancy character of respondent’s possession. In their ejectment complaint, they alleged that respondent occupied the subject land without paying rentals and that they needed the land for personal use. Respondent answered that the MCTC lacked jurisdiction because of an alleged tenancy relationship, supported by a certification from the Municipal Agrarian Reform Office (MARO). He likewise insisted on his ownership claim and noted that he had earlier filed a PARAB case.

PARAB Determination and Conflicting Proceedings

While the ejectment case was pending, the PARAB issued a decision on January 31, 1995 declaring respondent as tenant of the land and ordering maintenance of his peaceful possession. Petitioners appealed to the Department of the Agrarian Reform Adjudication Board (DARAB). Separately, on September 28, 1995, the MCTC rendered a decision ordering respondent to vacate the premises and to pay reasonable rentals and attorney’s fees. The MCTC ruled that there was a dearth of evidence showing that the land was agricultural or devoted to agricultural production and held that petitioners, as registered owners, had a better right to possession.

Without appealing the MCTC decision, respondent filed before the Regional Trial Court (RTC) of Angeles City a Petition for Prohibition with Preliminary Injunction and/or Temporary Restraining Order, seeking nullification of the MCTC decision on the ground that the MCTC had no jurisdiction because the issue was agrarian in nature.

RTC Proceedings and Denial of the Motion to Dismiss

The RTC issued a Temporary Restraining Order on October 30, 1995 restraining petitioners from enforcing the MCTC decision. After hearing, it granted a writ of preliminary injunction upon posting of a bond in the amount of P500,000.00 on November 29, 1995.

Petitioners answered and asserted that the MCTC could not be divested of jurisdiction merely by raising tenancy as a defense. They further contended that the disturbance compensation theory failed because, in 1956—the time respondent allegedly received the property—the legal provision for disturbance compensation was allegedly not yet in effect, and they also pointed to the alleged absence of proof of the conveyance.

At trial, respondent presented his evidence in chief. After he rested, petitioners filed a Motion to Dismiss, invoking, among others, that prohibition could not substitute for appeal and that MCTC jurisdiction was vested and determined by the allegations of the ejectment complaint in accordance with Rule 70 of the Rules of Court. They maintained the MCTC’s decision was, therefore, a valid exercise of its jurisdiction.

On February 25, 1998, the RTC denied the motion to dismiss. It treated the motion as a demurrer to evidence that, under Section 1, Rule 33 of the Rules of Court, could be granted only if it showed that the plaintiff had no right to the relief prayed for. The RTC also reasoned that the evidence presented raised an issue for resolution on whether the respondent court had jurisdiction over the subject matter of the case, and it held that denial of the motion was proper. Petitioners’ motion for reconsideration was denied on June 23, 1998.

Appellate Proceedings and the Present Petition

Petitioners filed a petition for certiorari in the Court of Appeals. On September 3, 1999, the Court of Appeals affirmed the RTC, holding there was no grave abuse of discretion. It emphasized that the denial order was interlocutory and not assailable via Rule 65, Rules of Court, and it added that the issues in the prohibition petition were genuine and substantial, requiring evidence from both parties.

Petitioners then sought review before the Supreme Court, challenging whether the RTC’s denial of the demurrer to evidence was attended by grave abuse of discretion. The Supreme Court initially denied a prior petition due to non-compliance with the requirement to attach a clearly legible duplicate original or certified true copy of the assailed decision. After petitioners re-filed within the reglementary period, the Court allowed the re-filing pursuant to Philippine Airlines v. Confesor.

In response, respondent argued that the RTC did not commit grave abuse of discretion because the MCTC lacked jurisdiction, and he pointed out that the PARAB decision was affirmed by the DARAB in a decision dated March 6, 2000.

Issues and Ruling

The Court framed the pivotal issue as whether the denial of the motion to dismiss by way of demurrer to evidence was afflicted with grave abuse of discretion amounting to lack or excess of jurisdiction.

The Court denied the petition, affirmed the Court of Appeals, and held that certiorari does not generally lie to review an interlocutory order denying a motion to dismiss even when filed as a demurrer to evidence after the plaintiff had presented and rested his case. The Court also recognized the exception only when denial is tainted with grave abuse of discretion amounting to lack or excess of jurisdiction.

Legal Basis and Reasoning

The Court upheld the Court of Appeals’ ruling. It ruled that, as a general rule, an order denying a demurrer to evidence is interlocutory, is not appealable, and is not ordinarily subject to certiorari. The proper course after such denial is for the defendant to present evidence, then to raise the demurrer issues on appeal if the judgment proves adverse.

It then addressed why, under the special circumstances of the case, respondent’s resort to prohibition before the RTC was proper. The Court found that two tribunals had exercised jurisdiction over cases involving the same subject matter, issue, and parties, and that their rulings were conflicting. It noted that the MCTC took cognizance of ejectment pursuant to Section 33 of Batas Pambansa Blg. 129, while DARAB’s rationale was that the controversy was agrarian because it arose out of or was connected with agrarian relations. The Court further relied on Section 50 of R.A. 6657, which vests in the DAR quasi-judicial powers to adjudicate agrarian reform matters, and on E.O. 129-A, which created the DARAB to assume adjudicatory functions.

The Court cited the DARAB Rules of Procedure, Rule II, Section 1, to emphasize DARAB’s primary and exclusive jurisdiction over agrarian disputes involving the implementation of R.A. 6657 and other enumerated agrarian laws. It stressed that if a prior tenancy relationship exists, the MCTC is divested of jurisdiction because the juridical tie compels the characterization of the controversy as an agrarian dispute. The Court reiterated that an agrarian dispute includes controversies relating to tenurial arrangements over lands devoted to agriculture, and it extends to incidents arising from the landlord-tenant relationship even if the arrangement had already been severed. It specifically treated the type of controversy in this case—dispossession by a former landlord of a former tenant claimed to have been given as compensation in consideration of renunciation of tenurial rights—as an agrarian dispute.

Against petitioners’ argument that questions of jurisdiction are questions of law resolvable without receiving evidence, the Court held that the issue determinative of jurisdiction was the real relationship between the parties. It explained that it was necessary for the parties to present evidence before the court could pass upon jurisdiction, especially when the demurrer involved the sufficiency of the evidence to support the prohibition application.

The Court also justified why prohibition was the ap

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