Dayrit vs. Norquillas

First-level courts have jurisdiction over forcible entry cases involving agricultural lands only when the dispute is not an agrarian dispute; when the two requisites under Section 50-A of RA 9700 are present—(1) an allegation from any party that the case is agrarian in nature, and (2) one of the parties is a farmer, farmworker, or tenant—the case must be referred to the DAR, which has primary jurisdiction over agrarian disputes.

Angelina Dayrit was the registered owner of two parcels of land in Bolisong, El Salvador, Misamis Oriental, covered by Original Certificate of Title No. P-13388 and Transfer Certificate of Title No. T-1804. In 1993, the parcels were placed under Comprehensive Agrarian Reform Program (CARP) coverage, resulting in the cancellation of her titles and the issuance of Certificates of Land Ownership Award (CLOAs) in favor of respondents as agrarian reform beneficiaries. Angelina pursued parallel administrative remedies before the Department of Agrarian Reform (DAR): a petition for annulment of the CLOAs before the DARAB and an application for exemption from CARP coverage.

Angelina Dayrit was the registered owner of two parcels of land located in Bolisong, El Salvador, Misamis Oriental, the first covered by Original Certificate of Title No. P-13388 and the second by Transfer Certificate of Title No. T-1804. In 1993, the parcels were placed under CARP coverage. Angelina's titles were cancelled, and new titles pursuant to CLOAs were issued in favor of respondents as agrarian reform beneficiaries. Angelina filed a petition for annulment of the CLOAs before the DARAB (Misamis Oriental Provincial Office) and simultaneously applied for exemption from CARP coverage with the DAR.

While the appeal of the petition for annulment was pending before the DARAB Manila Office, Angelina claimed that on September 17, 2006, respondents surreptitiously entered the property and refused to vacate despite repeated demands. This prompted her to file a complaint for forcible entry before the 7th Municipal Circuit Trial Court of Opol and El Salvador, Misamis Oriental. Respondents, in their answer, acknowledged that Angelina was the previous owner but asserted that she lost ownership over 16.6927 hectares when the lands were awarded to them as CARP beneficiaries, and consequently lost her right of possession. They maintained that they remained owners despite Angelina's pending petition for annulment of the CLOAs, and that Angelina could not claim forcible entry having already lost her right of possession.

The MCTC ruled in favor of Angelina, finding that she was in prior possession of the parcels and that respondents should not have taken the law into their own hands. The MCTC held that the forcible entry suit pertained only to physical possession for the maintenance of public order and did not relate to ownership issues cognizable by the DARAB. On appeal, the RTC affirmed the MCTC in its entirety, adding that the lower courts have exclusive original jurisdiction over forcible entry and unlawful detainer under the Judiciary Reorganization Act of 1980, and that the issue of physical possession over agricultural lands is distinct from the issue of disposition and alienation cognizable by the DAR. The CA reversed, finding that the DARAB had jurisdiction because the issue of possession was linked to an agrarian dispute arising from the issuance of CLOAs to respondents, and that the complaint should have been dismissed for litis pendentia due to the pending DARAB proceeding.

• Jurisdiction over Forcible Entry: Petitioner maintained that while the DAR has the power of administration and disposition of agricultural lands, courts have jurisdiction over actions for forcible entry and unlawful detainer, as the instant case involves only the issue of possession and does not involve adjudication of ownership or an agrarian matter.
• Independence of Possessory Issues: Petitioner cited case law upholding the courts' jurisdiction over possessory matters despite involving agricultural lands, arguing that the issue of physical possession is independent from the question of disposition or alienation. Maintenance of public order, the purpose of summary remedies for forcible entry, cannot be hindered by invoking an agrarian dispute.
• DAR Exemption Ruling: Petitioner argued that the DAR, in its June 8, 2011 Decision, had already resolved her application for exemption and ruled that the parcels of land are exempted from CARP coverage.
• Prejudicial Question: Petitioner argued that the DAR proceedings constituted an administrative prejudicial question that warranted the abeyance of judicial proceedings.

• Agrarian Dispute: Respondents maintained that the case is an agrarian dispute under the original and primary jurisdiction of the DARAB, as the filing of the forcible entry complaint was an offshoot of the enforcement of their rights and obligations under the CLOAs issued to them.
• Transfer of Ownership: Respondents argued that the case relates to the terms and conditions of the transfer of ownership, which necessarily includes possession, from the landowner to the beneficiaries.

• Jurisdiction: Whether the MCTC has jurisdiction over the instant complaint for forcible entry.

• Jurisdiction: No. The MCTC has no jurisdiction over the complaint for forcible entry because the case constitutes an agrarian dispute cognizable by the DAR through the DARAB, the two requisites for automatic referral under Section 50-A of RA 9700 having been satisfied.

• Jurisdiction: Jurisdiction over the subject matter is conferred by law and determined by the allegations in the complaint. While Section 33 of the Judiciary Reorganization Act of 1980 grants first-level courts exclusive original jurisdiction over forcible entry cases, Section 50 of the CARL (RA 6657), as amended by Section 50-A of RA 9700, vests the DAR with primary jurisdiction over agrarian disputes. The Court clarified that the controlling aspect is the nature of the dispute—whether agrarian or not—and not the character of the subject land. David vs. Cordova established that first-level courts have jurisdiction over ejectment cases even when the land is public in character, provided the case is not an agrarian dispute. Chailese Development Company, Inc. vs. Dizon clarified the two requisites for automatic referral under RA 9700: (1) an allegation from any party that the case is agrarian in nature, and (2) one of the parties is a farmer, farmworker, or tenant. Both requisites were met here. Respondents consistently alleged the controversy was agrarian in nature, invoking their status as CARP beneficiaries under the CLOAs. Their status as farmers was recognized by the CA and the DAR Secretary and was not disputed by Angelina; it was further cemented by the award of the lands to them through CLOAs. Because respondents entered the property by virtue of the CLOAs, the controversy clearly relates to the terms and conditions of transfer of ownership to agrarian reform beneficiaries, making it an agrarian dispute. RA 9700's amendment is procedural in nature and was applied retroactively to the pending case. The Court agreed with the CA's dismissal for lack of jurisdiction, noting that the DAR exemption proceedings had not yet attained finality, so the rights of the parties may still change.

• Jurisdiction over Forcible Entry Involving Agricultural Lands — First-level courts have exclusive original jurisdiction over forcible entry cases under Section 33 of the Judiciary Reorganization Act of 1980. However, this jurisdiction is divested when the case constitutes an agrarian dispute under the CARL, as amended. The controlling aspect is the nature of the dispute (agrarian or not), not the character of the subject land. Courts retain jurisdiction over possessory actions involving agricultural lands to determine physical possession, as this issue is independent of the question of disposition and alienation cognizable by the DAR—but only when the dispute is not agrarian in nature.
• Two Requisites for Automatic Referral under Section 50-A of RA 9700 — For a case to be automatically referred to the DAR, the following must concur: (a) there is an allegation from any one or both of the parties that the case is agrarian in nature; and (b) one of the parties is a farmer, farmworker, or tenant. Mere allegation of the existence of an agrarian dispute satisfies the first requisite. As to the second, proof must be adduced as to the person's status as farmer, farmworker, or tenant.
• Retroactive Application of RA 9700 — Section 50-A of RA 9700 is procedural in nature and may be applied retroactively to actions pending and undetermined at the time of its passage, including complaints for forcible entry before first-level courts. The amendment merely reinforced the jurisdiction of the DAR already provided under Section 50 of RA 6657 and did not deviate from it.
• Definition of Agrarian Dispute — Under Section 3(d) of the CARL, as amended, an agrarian dispute refers to any controversy relating to tenurial arrangements over lands devoted to agriculture, including any controversy relating to compensation of lands acquired under the CARL and other terms and conditions of transfer of ownership from landowner to farmworkers, tenants, and other agrarian reform beneficiaries.

• "Thus, David should not be understood that jurisdiction on ejectment cases of whatever nature falls on first-level courts; it should be read and understood to provide that first-level courts have jurisdiction on ejectment cases even if the land is public in character as long as the case is not an agrarian dispute." — This passage clarifies the proper reading of David vs. Cordova, distinguishing between the public character of land and the existence of an agrarian dispute as the controlling factor for jurisdiction.
• "The controlling aspect, therefore, is the nature of the dispute (i.e., agrarian or not) and not the character of the subject land." — This formulation articulates the ratio decidendi: jurisdiction turns on whether the dispute is agrarian, not on whether the land is public or private.
• "As respondents entered the subject parcel of lands by virtue of the CLOAs, this entry, despite being characterized by Angelina as forcible entry, is clearly a controversy relating to and arising from the terms and conditions of transfer of ownership to agrarian reform beneficiaries." — This passage applies the definition of agrarian dispute to the facts, concluding that entry under CLOAs transforms the forcible entry claim into an agrarian controversy.

• David vs. Cordova, 502 Phil. 626 (2005) — Followed and clarified. The Court upheld MCTC jurisdiction over forcible entry because the dispute was not agrarian in nature, even though the land was public. The decision was distinguished to show that not all ejectment cases are cognizable by first-level courts; those involving agrarian disputes are excluded.
• Chailese Development Company, Inc. vs. Dizon, 826 Phil. 51 (2018) — Followed. Clarified the two requisites for automatic referral under Section 50-A of RA 9700 and established the retroactive application of the procedural amendment to pending cases.
• Pajuyo vs. Court of Appeals, 474 Phil. 557 (2004) — Cited for the principle that the sole issue in ejectment proceedings is possession de facto, not possession de jure, and that title is not involved.
• Department of Agrarian Reform vs. Cuenca, 482 Phil. 208 (2004) — Cited for the principle that doubts as to the jurisdiction of the DAR on the implementation of the CARP should be resolved in its favor.

• Section 33(2), Judiciary Reorganization Act of 1980 (BP 129), as amended — Grants first-level courts exclusive original jurisdiction over cases of forcible entry and unlawful detainer, with the proviso that when the defendant raises the question of ownership and possession cannot be resolved without deciding ownership, the issue of ownership shall be resolved only to determine the issue of possession. Applied to establish the general jurisdiction of MCTC over forcible entry, subject to the limitation that agrarian disputes fall under DARAB jurisdiction.
• Section 50, Comprehensive Agrarian Reform Law of 1988 (RA 6657), as amended — Vests the DAR with primary jurisdiction to determine and adjudicate agrarian reform matters and exclusive original jurisdiction over all matters involving the implementation of agrarian reform. Applied as the statutory basis for DARAB jurisdiction over agrarian disputes.
• Section 50-A, RA 9700 (amending RA 6657) — Provides that no court or prosecutor's office shall take cognizance of cases pertaining to the implementation of the CARP except those under Section 57 of RA 6657. Mandates automatic referral to the DAR when there is an allegation that the case is agrarian in nature and one party is a farmer, farmworker, or tenant. Applied retroactively to the instant case to divest the MCTC of jurisdiction.
• Section 3(d), CARL (RA 6657), as amended — Defines "agrarian dispute" as any controversy relating to tenurial arrangements over lands devoted to agriculture, including disputes concerning transfer of ownership from landowner to farmworkers, tenants, and other agrarian reform beneficiaries. Applied to classify the instant controversy as an agrarian dispute.

• Gesmundo, C.J. — concurred.
• Carandang, J. — concurred.
• Inting, J. — concurred.
• Zalameda, J. — concurred.
• M. Lopez, J. — concurred.
• Gaerlan, J. — concurred.
• Rosario, J. — concurred.
• J. Lopez, J. — concurred.
• Marquez, J. — concurred.
• Perlas-Bernabe, J. — wrote a Separate Concurring Opinion.
• Leonen, J. — wrote a Separate Concurring Opinion.
• Caguioa, J. — wrote a Concurring Opinion. Justice Caguioa's observations were expressly relied upon in the majority opinion to clarify that David vs. Cordova did not lay down a blanket rule that all ejectment cases are cognizable by first-level courts; rather, the Court sustained MCTC jurisdiction in David because the case did not involve an agrarian dispute, not merely because it was summary in nature.
• Lazaro-Javier, J. — wrote a Separate Concurring Opinion. Justice Lazaro-Javier's reflections were relied upon in the majority opinion to identify that the case meets the two requirements for automatic referral under RA 9700 as summarized in Chailese.
• Dimaampao, J. — on official leave but voted.