Title Heirs of the Late Herman Rey Santos v.

Court of Appeals
G.R. No. 109992, March 7, 2000
Ynares-Santiago
Facts A parcel of land in Plaridel, Bulacan was levied on execution by the MTC of
Bulacan in 1989. The land was sold at public auction in 1990 with Santos, [now
substituted by his heirs] as the sole bidder.

Santos registered the deed of sale in bulacan in October 1990 after Exequiel
Garcia failed to exercise his right of redemption within the reglementary period.

In 1992, Garcia filed a petition for injunction and damages with preliminary
injunction with the DARAB, praying that petitioner be enjoined from preventing
private respondent from gathering the mango fruits. DARAB issued an order
allowing the gathering of the mango fruits and directing that the proceeds thereof
be deposited with the DARAB.

Subsequently, Garcia also filed to redeem his land. This petition was dismissed.
Meanwhile, Pantaleon Antonio filed a motion to intervene with the DARAB claiming
that he is affected in his rights over the mango trees which he tended for that
season. DARAB suspended the claim of Antonio pending the resolution of the
ownership issue.

Later, Antonio filed a motion to withdraw intervenors deposited share which was
granted by DARAB, also recognizing Antonio as the duly constituted agricultural
tenant of the land. This order was affirmed by the CA. Hence, this petition.

Issue Whether the jurisdiction is under PARAD since there is an issue of ownership.
Ruling No. Agrarian dispute is under the jurisdiction of DARAB, however in the case, there
is no agrarian dispute since the parties are contending as to the ownership of the
land. And the parties have no tenurial, leasehold, or any agrarian relations. So
DARAB has no jurisdiction. The issue of the case is ownership which is under the
jurisdiction of the RTC.
Title FEDERICO SORIANO, et. al. vs. ANA SHARI B. BRAVO, et. al.,
G.R. No. 152086, December 15, 2010
LEONARDO-DE CASTRO, J.
Facts It was a case which involves agricultural lands located at Pangasinan, with a total
land area of 24.5962 hectares (subject properties). The subject properties were
originally owned by spouses Patricio Posadas and Josefa Quintana. Upon the
spouses Posadas’ demise, the subject properties were subdivided, distributed, and
transferred – by extrajudicial settlement and/or sale – to their heirs.

This case was a Petition for Review on Certiorari of the Decision of the Court
Appeals affirming in toto the Decision of the Department of Agrarian Reform
Adjudication Board (DARAB), which, in turn, affirmed in toto the Decision of
Provincial Agrarian Reform Adjudicator (PARAD) Domiciano L. Placido (Placido).
PARAD Placido adjudged, among other things, that the subject properties were
exempt from the coverage of the operation land transfer (OLT) program of the
Government under Presidential Decree No. 27, otherwise known as the Tenants
Emancipation Decree, and Republic Act No. 6657, otherwise known as the
Comprehensive Agrarian Reform Law (CARL).

Issue WON DARAB has jurisdiction?

Ruling In Sta. Rosa Realty Development Corporation v. Amante,20 the Court pointed out
that the jurisdiction of the DAR under the aforequoted provision is two-fold. The first
is essentially executive and pertains to the enforcement and administration of the
laws, carrying them into practical operation and enforcing their due observance,
while the second is judicial and involves the determination of rights and obligations
of the parties.

The material allegations and reliefs sought in respondents’ Complaint essentially

established a case involving the rights and obligations of respondents and
defendants as landlords and agricultural tenants/lessees, respectively, taking into
account their Compromise Agreement; as well as the fixing and collection of lease
rentals. The DARAB properly took cognizance of the case as it constituted agrarian
disputes, well-within the jurisdiction of the DARAB under Rule II, Section 1,
paragraphs (a) and (b) of the 1994 DARAB Rules.
Title REMIGIO ISIDRO v. THE HON. COURT OF APPEALS (SEVENTH DIVISION) AT
NATIVIDAD GUTIERREZ
GR No. L-105586 Disyembre 15, 1993
PADILLA, J.
Doctrin An agrarian dispute refers to any controversy relating to tenurial arrangements,
e whether leasehold, tenancy, stewardship or otherwise, over lands devoted to
agriculture, including disputes concerning farm workers associations or
representation of persons in negotiating, fixing, maintaining, changing or seeking to
arrange terms or conditions of such tenurial arrangements.
Facts Respondent, Natividad Gutierrez is the owner of a parcel of land with an area of 4.5
hectares located in Barrio Sta. Cruz, Gapan, Nueva Ecija. In 1985, Aniceta Garcia,
sister of private respondent and also the overseer of the latter, allowed petitioner
Remigio Isidro to occupy the swampy portion of the abovementioned land,
consisting of one (1) hectare, in order to augment his (petitioner’s) income to meet
his family’s needs. The occupancy of a portion of said land was subject to the
condition that petitioner would vacate the land upon demand. Petitioner occupied
the land without paying any rental and converted the same into a fishpond.

In 1990, private respondent through her overseer demanded from petitioner the
return of the land, but the latter refused.

A complaint for unlawful detainer was filed by private respondent against petitioner
before the Municipal Trial Court (MTC) of Gapan, Nueva Ecija. MTC on  30 May
1991, dismissed the complaint, ruling that the land is agricultural and therefore the
dispute over it is agrarian which is under the original and exclusive jurisdiction of
the courts of agrarian relations as provided by law. Private respondent filed an
appeal before the RTC of Gapan, Nueva Ecija, which affirmed MTC’s decision in
toto. Private respondent appealed to CA, CA reversed and set aside the decision of
the RTC. Petitioner moved for reconsideration but was denied. Hence, this petitiom

Issue Whether or not the Municipal Trial Court has the jurisdiction in this case.
Ruling Yes. An agrarian dispute refers to any controversy relating to tenurial
arrangements, whether leasehold, tenancy, stewardship or otherwise, over lands
devoted to agriculture, including disputes concerning farm workers associations or
representation of persons in negotiating, fixing, maintaining, changing or seeking to
arrange terms or conditions of such tenurial arrangements. It includes any
controversy relating to compensation of lands acquired under Republic Act No.
6657 and other terms and conditions of transfer of ownership from landowners to
farm workers, tenants and other agrarian reform beneficiaries, whether the
disputants stand in the proximate relation of farm operator and beneficiary,
landowner and tenant, or lessor and lessee.It is irrefutable in the case at bar that
the subject land which used to be an idle, swampy land was converted by the
petitioner into a fishpond. And it is settled that a fishpond is an agricultural land.

But a case involving an agricultural land does not automatically make such case an
agrarian dispute upon which the DARAB has jurisdiction.
(Reiterates essential requisites of tenancy relationship)
The fact remains that the existence of all the requisites of a tenancy relationship
was not proven by the petitioner. In the absence of a tenancy relationship, the
complaint for unlawful detainer is properly within the jurisdiction of the Municipal
Trial Court.