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JOSE MENDOZA v. NARCISO GERMINO

FACTS:

The case involves a complaint for forcible entry filed by the petitioners, Jose Mendoza and Aurora C. Mendoza, against the respondent, Narciso Germino. The petitioners claimed that they were the registered owners of a five-hectare parcel of land in Soledad, Sta. Rosa, Nueva Ecija, and that the respondent unlawfully entered the property without their consent. The respondents filed an answer claiming that the petitioners' brother, Benigno Germino, was their agricultural lessee, and he was the one cultivating the land. The petitioners then filed a motion to remand the case to the Department of Agrarian Reform Adjudication Board (DARAB) due to the tenancy issue raised. The Municipal Trial Court (MTC) granted the motion and remanded the case to the DARAB. The petitioners subsequently filed an amended complaint with the Provincial Agrarian Reform Adjudicator (PARAD), impleading Benigno as an additional defendant. The petitioners alleged that Benigno unlawfully entered the property and withheld possession and its produce. The PARAD found in favor of the petitioners and ordered the respondents to vacate the property and pay 500 cavans of palay as actual damages. The respondents appealed to the DARAB, arguing that the referral to the DARAB was void due to the enactment of Republic Act (R.A.) No. 6657. The DARAB affirmed the PARAD decision. The respondents then filed a petition for review with the Court of Appeals (CA) which set aside the DARAB decision and remanded the case to the MTC. The CA denied the subsequent motion for reconsideration, leading to the petitioner filing the present petition. The core issue is whether the MTC or the DARAB has jurisdiction over the case.

ISSUES:

  1. Whether the MTC (Municipal Trial Court) or the DARAB (Department of Agrarian Reform Adjudication Board) has jurisdiction over the case.

RULING:

  1. The Supreme Court ruled that jurisdiction lies with the MTC, not the DARAB. The allegations and reliefs prayed for in the original complaint filed with the MTC clearly indicated that the action was for forcible entry, which falls under the exclusive original jurisdiction of the MTC.

PRINCIPLES:

  1. Jurisdiction Over Subject Matter: Jurisdiction over the subject matter is determined by the allegations in the complaint and is defined exclusively by the Constitution and the law, not by the voluntary act or the agreement of the parties.

  2. Forcible Entry: The MTC has exclusive original jurisdiction over cases of forcible entry and unlawful detainer as per Batas Pambansa Blg. 129, as amended by R.A. No. 7691.

  3. Agrarian Dispute: For a case to involve an agrarian dispute, there must be an allegation of tenancy with essential requisites including: parties being the landowner and tenant, subject being agricultural land, consent, purpose of agricultural production, personal cultivation, and sharing of harvest or payment of rental.

  4. Tenancy Claims as a Defense: An allegation or claim of tenancy by the defendant does not automatically divest the MTC of jurisdiction. It is the MTC's duty to hear the case to determine whether it has jurisdiction over the matter.

  5. Amendment of Complaint: Amendment of the complaint does not confer jurisdiction upon the DARAB, especially when the nature of the dispute as described still falls within the regular court's jurisdiction.