CaseDig: Villacastin vs. Pelaez

G.R. No. 170478; May 22, 2008
Posted by: Ana R. Bonita on July 30, 2018

FACTS:
  • On June 29, 1976, respondent Paul Pelaez and his wife mortgaged their agricultural lands to the Development Bank of the Philippines (DBP).
  • For failure of the Pelaez spouses to pay their mortgage obligation, the properties were foreclosed and subsequently sold at public auction.
  • The purported tenants of the properties filed an action to annul the mortgage, foreclosure and sale of the properties, claiming that they are the owners thereof under Presidential Decree No. 27.
  • In the meantime, on May 10, 1988, petitioners filed a Complaint for Forcible Entry with Prayer for a Writ of Preliminary Mandatory Injunction with the First Municipal Circuit Trial Court (MCTC) against respondent and a certain Elesio Monteseven.
  • The complaint averred that plaintiffs (petitioners herein) are the owners and actual possessors of the subject landholding and that defendants, having entered the property through stealth and strategy, unlawfully deprived plaintiffs of possession thereof.
  • Respondent countered that he is the owner of the subject property, which was foreclosed by the DBP and later purchased by petitioners at an auction sale.
  • Petitioners, however, were allegedly never in possession of the subject property as they failed to apply for a writ of possession therefor.
  • Respondent further claimed that he had redeemed the property on March 3, 1988 and accordingly reacquired possession thereof.
  • Meanwhile, the Provincial Agrarian Reform Adjudicator in Cebu rendered a decision in in favor of the tenants. This decision was affirmed by the DARAB in February 22, 2000.
  • On January 6, 2000, the MCTC rendered judgment in favor of petitioners. The RTC affirmed the MCTC decision on March 10, 2004.
  • The Court of Appeals, however, ruled that regular courts should respect the primary jurisdiction vested upon the DARAB in cases involving agricultural lands such as the property subject of this case. Accordingly, it set aside the decision rendered by the RTC and the MCTC, and dismissed the complaint for forcible entry filed by petitioners in this case.
ISSUE:
  • Whether or not MCTC acquired jurisdiction over the case.
HELD:
  • Jurisdiction over the subject matter is determined by the allegations of the complaint.
  • In ascertaining, for instance, whether an action is one for forcible entry falling within the exclusive jurisdiction of the inferior courts, the averments of the complaint and the character of the relief sought are to be examined.
  • A review of the complaint reveals that the pertinent allegations thereof sufficiently vest jurisdiction over the action on the MCTC.
  • The complaint alleges as follows:
"That the plaintiffs are the owners and legal as well as actual possessors of a parcel of agricultural land more particularly described as follows:
 x x x
That the defendant, sometime in the second week of March 1988, by strategy and through stealth entered the above-described land of the plaintiffs and took possession thereof; thus, depriving said plaintiffs of the possession thereof;

That several demands were made the plaintiffs upon the defendants to restore to them the possession of the above-described parcel of land; but, defendants refused and still refuse to restore possession of said property to the plaintiffs.

  • Petitioners' action is clearly for the recovery of physical or material possession of the subject property only, a question which both the MCTC and the RTC ruled petitioners are entitled to. It does not involve the adjudication of an agrarian reform matter, nor an agrarian dispute falling within the jurisdiction of the DARAB.
  • Courts have jurisdiction over possessory actions involving public or private agricultural lands to determine the issue of physical possession as this issue is independent of the question of disposition and alienation of such lands which should be threshed out in the DAR. Thus, jurisdiction was rightfully exercised by the MCTC and the RTC.
  • WHEREFORE, the petition is GRANTED. The Decision of the Court of Appeals and its Resolution are REVERSED and SET ASIDE.  The Decision of the Regional Trial Court affirming the decision of the Municipal Circuit Trial Court is REINSTATED. No pronouncement as to costs.