By: Zennia Marie V. Deleonio
FACTS:
Petitioner filed a Complaint for unlawful detainer against respondent with the MTCC, alleging that it became the owner of the parcel of land by virtue of the Deed of Sale executed between petitioner and Philippine National Bank (PNB), the previous owner of the land; that respondent had been occupying the subject land by reason of PNB's tolerance. Respondent refused to vacate the land, despite repeated demand from the petitioner.
A Motion to Dismiss was filed by the petitioner contending that the MTCC lacked jurisdiction over the case as it involved the implementation of agrarian reform and should fall within the exclusive and original jurisdiction of the Department of Agrarian Reform (DAR). In the Supplemental Position Paper filed by the respondent on May 25, 1998, he insisted that there was a pending case between the same parties involving the same property and the same issues before the Department of Agrarian Reform Adjudication Board (DARAB) which was filed.
MTC rendered a Decision for the respondent to vacate the subject land. Thus it was appealed to the RTC. Further, the DARAB rendered a decision which held that the subject matter is not within its jurisdiction. It was further held that in order to give DARAB jurisdiction over the case, it was necessary that the complaint itself should contain statements of facts that would bring the party clearly within the class of cases under the DARAB's jurisdiction. The RTC held: the MTC should have yielded to the DARAB as the quasi-judicial body clothed with primary jurisdiction over agrarian issues; in cases where agrarian issues are raised, primary jurisdiction is with the DARAB to avoid conflict of jurisdiction with the DAR and for the proper application of the Comprehensive Agrarian Reform Law (R.A. No. 6657);
ISSUE:
Whether or not MTC has jurisdiction over agrarian issues.
RULING:
No, the RTC rendered a Decision reversing and setting aside the MTC judgment. The RTC held: the MTC should have yielded to the DARAB as the quasi-judicial body clothed with primary jurisdiction over agrarian issues; trial court judges had been explicitly reminded by the Court through Administrative Circular 8-9224 that in cases where agrarian issues are raised, primary jurisdiction is with the DARAB to avoid conflict of jurisdiction with the DAR and for the proper application of the Comprehensive Agrarian Reform Law (R.A. No. 6657); the MTC should have heard the Motion to Dismiss filed by the private respondent for the precise purpose of determining whether or not it possessed jurisdiction over the case; it was clear that the private respondent was seeking the protection of the agrarian laws when he alleged that there was a pending case before the DARAB and that a copy of the complaint in the DARAB was submitted to the trial court; it is provided under Section 7 of R.A. No. 6657 and under Executive Order No. 360, Series of 1989, that the DAR has the right of first refusal of the sale or disposition of the acquired assets of the PNB, the latter being a government financial institution. Petitioner moved for the reconsideration of said decision.
