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FRANCISCO RAMOS v. STATELAND INVESTMENT CORPORATION

FACTS:

The American Realty Corporation (ARC) executed two real estate mortgage contracts in favor of the Bank of America using five parcels of land in Bulacan as security. Integrated Credit and Cooperative Service (ICCS) purchased the properties at a public auction after the mortgages were foreclosed. ICCS then sold the property to Stateland Investment Corporation (SIC). SIC discovered that Francisco Ramos and his family were occupying a two-story house on a portion of the property. SIC informed Ramos that they acquired the property and hired security guards to prevent squatters. Ramos and the other occupants filed a complaint with the Department of Agrarian Reform (DAR) Provincial Adjudication Board against SIC and Reynaldo Litonjua. SIC also filed a complaint for ejectment against Ramos in the Municipal Trial Court (MTC). Ramos admitted that SIC was the owner but claimed to be a tenant since 1974.

The MTC ruled in favor of SIC, stating that they had jurisdiction and that SIC was the owner of the house as the registered owner of the land. Ramos filed a Notice of Appeal but later withdrew it, leading to the MTC decision becoming final and executory. Ramos then petitioned the Regional Trial Court (RTC) to nullify the MTC decision, alleging lack of jurisdiction and denial of due process. SIC filed a motion to dismiss, citing res judicata and forum shopping. Ramos later withdrew his appeal to the RTC, resulting in his estoppel from challenging the MTC's jurisdiction.

The RTC denied SIC's motion to dismiss and declared the MTC decision null and void, considering it an agrarian case falling under the jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB). SIC appealed this resolution to the Court of Appeals (CA), which concluded that the MTC had jurisdiction over the case and that Ramos had failed to prove his tenancy claim. The CA also stated that Ramos was barred from filing a petition to annul the MTC decision since he had withdrawn his appeal. Ramos filed a petition for review on certiorari, contesting the CA's reversal of the RTC's resolution and claiming to be a bona fide agricultural lessee-tenant in his answer to the MTC.

ISSUES:

  1. Whether the Municipal Trial Court (MTC) had jurisdiction over the respondent's action for unlawful detainer.

  2. Whether the petitioner availed of the proper remedy from the MTC decision in favor of the respondent.

  3. Whether or not the MTC has jurisdiction over an action for unlawful detainer when tenancy is averred as a special defense.

  4. Whether or not the DARAB has primary and exclusive jurisdiction over the case involving the dispute between the parties.

  5. Whether the Municipal Trial Court (MTC) has jurisdiction over the issue of material possession of the house

  6. Whether the filing of an Urgent Motion in the DARAB by the respondent vests jurisdiction to resolve the issue of possession of the house

  7. Whether the DARAB decision on the issue of tenancy and land coverage would be conclusive on the issue of possession of the house

  8. Whether the Court of Appeals erred in reversing the resolution of the Regional Trial Court (RTC).

  9. Whether the decision of the Municipal Trial Court (MTC) had become final and executory.

RULING:

  1. The MTC had jurisdiction over the respondent's action. An action for unlawful detainer is within the exclusive jurisdiction of the MTC, Metropolitan Circuit Trial Court, or Metropolitan Trial Court, unless it involves agricultural tenancy laws or is otherwise expressly provided by law. In this case, the complaint did not involve an agrarian dispute but only sought the recovery of possession of real property, making it within the jurisdiction of the MTC.

  2. The petitioner did not avail of the proper remedy from the MTC decision. The proper remedy from an adverse decision of the MTC is to appeal to the Regional Trial Court (RTC), and if the RTC affirms the decision, to file a petition for review with the Court of Appeals (CA). However, the petitioner opted to withdraw his appeal, and as such, he was barred from filing a petition to annul the decision of the MTC. The petitioner was effectively litigating the same issues raised in the MTC by filing a petition to annul the decision in the RTC.

  3. The MTC retains jurisdiction over an action for unlawful detainer even when tenancy is averred as a special defense. The MTC is required to conduct a preliminary conference and may even conduct a hearing to determine if the tenancy relationship is the real issue. If it is established that tenancy is indeed the issue, the MTC should dismiss the case for lack of jurisdiction.

  4. The DARAB does not have primary and exclusive jurisdiction over the case. The dispute between the parties involves the eviction from a two-storey house and not from the landholding. The action is one for unlawful detainer, and the DARAB's jurisdiction is limited to agrarian disputes pertaining to agricultural lands covered by the Comprehensive Agrarian Reform Law (CARP) and other agrarian laws.

  5. The MTC has jurisdiction over the issue of material possession of the house. The MTC is not required to apply agrarian reform laws or regulations in resolving the issue, and it is not interwoven with the issue of tenancy over the landholding in DARAB Case No. 4471.

  6. The filing of an Urgent Motion in the DARAB by the respondent does not vest jurisdiction to resolve the issue of possession of the house. Jurisdiction over the subject matter and nature of an action cannot be conferred on the court by consent or waiver of the party.

  7. The DARAB decision on the issue of tenancy and land coverage is not conclusive on the issue of possession of the house. The DARAB decision did not enjoin the respondent from causing the petitioner's eviction from the house.

  8. The Court held that the Court of Appeals ruling, which reversed the resolution of the RTC, was accurate. The decision of the MTC had become final and executory.

PRINCIPLES:

  • The jurisdiction of the court or tribunal over the subject matter of the action is determined exclusively by the Constitution and the law. Jurisdiction cannot be conferred by the voluntary act or agreement of the parties, nor can it be acquired through or waived, enlarged, or diminished by their act or omission.

  • Agricultural tenancy or agrarian reform laws cover agricultural lands or farmlands devoted to agricultural activity. Agrarian disputes include controversies relating to tenurial arrangements over such lands, including disputes concerning compensation of lands acquired under agrarian reform laws and other transfer of ownership terms and conditions.

  • An action for unlawful detainer is within the exclusive jurisdiction of the MTC, unless it involves agricultural tenancy laws or is otherwise expressly provided by law.

  • The MTC retains jurisdiction over an action for unlawful detainer even when tenancy is averred as a special defense.

  • The DARAB has primary and exclusive jurisdiction over agrarian disputes pertaining to agricultural lands covered by CARP and other agrarian laws.

  • Jurisdiction over the subject matter and nature of an action cannot be conferred on the court by consent or waiver of the party.

  • Active participation of the parties in proceedings does not automatically vest jurisdiction in a court or tribunal.

  • Estoppel does not apply to confer jurisdiction to the court or tribunal that has no jurisdiction over the nature of the action.

  • In an ejectment suit, the only issue is possession of the leased premises, not ownership of the lot.

  • Jurisdiction is conferred only by law.

  • The remedy from the decision of the MTC is to appeal in due course to the RTC.

  • Withdrawing an appeal from the RTC does not affect the finality and executory nature of the decision of the MTC.