Sumawang vs. De Guzman

Jurisdiction over an ejectment case is determined by the material allegations of the complaint, and the MTC does not lose jurisdiction over an ejectment case merely because a party raises tenancy as a defense. The court must receive evidence to determine the tenancy allegation, and only if tenancy is shown to be the real issue should it dismiss the case for lack of jurisdiction. A tenancy relationship cannot be presumed; all six requisites must be proven, and the absence of any one requisite prevents the alleged tenant from being considered a de jure tenant.

The case involves a parcel of agricultural land in Guimba, Nueva Ecija, originally part of a larger tract owned by Gloria Zulueta Rominquit and placed under the Comprehensive Agrarian Reform Program. The respondent, Engr. Eric D. De Guzman, was issued Emancipation Patent No. 288843 over the property, designated as Lot 33, and subsequently obtained TCT EP No. 31683. The petitioner, Amando G. Sumawang, claimed to have been cultivating the land since 1965 and alleged that he was a farmer-beneficiary. The central dispute concerns whether the petitioner was an agricultural tenant of the respondent or merely a farm worker, which determines whether the case falls under the jurisdiction of the MTC or the DARAB.

On June 8, 1999, Engineer Eric de Guzman filed a complaint for unlawful detainer with damages in the MTC of Guimba, Nueva Ecija against Amando G. Sumawang. The respondent alleged that the President of the Philippines issued Emancipation Patent No. 288843 in his favor on August 19, 1988, over a parcel of agricultural land designated as Lot 33, with an area of 9,970 square meters, located in Macatcatuit, Guimba, Nueva Ecija. On December 12, 1988, the Register of Deeds issued TCT EP No. 31683 over the landholding. The respondent alleged that he leased a portion of the property to the petitioner, where the latter constructed a small hut and remitted rentals; however, in the early part of 1999, the petitioner failed to pay the agreed rentals, and despite demand on March 10, 1999, he failed to vacate the property.

In his answer, the petitioner alleged that Gloria Zulueta Rominquit owned a large tract of agricultural land designated as Lot 1402, placed under the Comprehensive Agrarian Reform Law. He claimed that he cultivated a portion of the property and was one of the farmer-beneficiaries listed in the Office of the Municipal Agrarian Reform. Sometime in 1965, he swapped the portion he was cultivating with Lot 33, which was cultivated by Antonio Ferrer, and thenceforth cultivated that lot. In 1994, he built a house of strong materials on the property where he and his family resided. He sought the assistance of his first cousin, Judge Felix de Guzman, the respondent's father, to secure a patent and title over the property, but the respondent allegedly secured through fraud an emancipation patent and title over the property in his name. The petitioner interposed the defense of lack of jurisdiction.

The respondent adduced evidence that per Parcellary Mapping Survey (PMS) No. 067, the subject property was designated Lot 12011, with an area of 9,100 square meters, covered by CLT No. 0114427 issued to Antonio Ferrer; but per final survey, the property was designated as Lot 33, with an area of 9,970 square meters. The respondent was granted Emancipation Patent No. 288843 over Lot 33, and TCT EP No. 31683 was issued. He declared the property under his name under Tax Declaration No. 94-10032-00515, free of any encumbrance, after paying amortizations to the Land Bank of the Philippines. During the period from 1991 to 1997, he employed the petitioner as a farmer-worker to whom he remitted sums of money for cultivation expenses such as soil, fertilizer, seedlings, and rentals for a rotorator.

The petitioner, for his part, presented certifications from former barangay captains that, since 1969, he had been the tenant on the farmland covered by CLT No. 0114427 under the name of Antonio Ferrer. He claimed that in 1987, he built a house of strong materials thereon, and in 1991, the respondent, through his father Judge Felix de Guzman, suggested a sharing system whereby the respondent would provide monetary assistance for cultivation expenses and would share in the produce net of expenses.

• Error in CA Conclusion: The petitioner argued that the CA erred in concluding that it was not prepared to declare him a tenant, and in concluding that his occupation of the subject land was by mere tolerance of the respondent without any contract between them, making him bound by an implied promise to vacate upon demand.
• Estoppel: The petitioner argued that the CA gravely erred in not taking cognizance of the doctrine of estoppel against the respondent.
• Non-application of R.A. 6657: The petitioner argued that the CA gravely erred in not applying the provisions of R.A. 6657 (New CARP Law), as applied by the RTC, considering that he had met the six requirements that concur to make a tenancy relationship.
• Farmer-Beneficiary Status: The petitioner asserted that he had been a farmer-beneficiary of the land since 1965, and even after the respondent secured title over the property, the latter allowed him to cultivate the property, supplied him with farm inputs and implements, and shared the harvests on a 50-50 basis net of costs of production. He asserted that he was the agricultural tenant of the respondent and not merely his farm worker, hence the dispute was within the exclusive jurisdiction of the DARAB.

N/A — The decision does not recount the respondent's arguments before the Supreme Court.

• Jurisdiction of the MTC: Whether the MTC had jurisdiction over the unlawful detainer action filed by the respondent.
• Existence of Tenancy Relationship: Whether the petitioner was the agricultural tenant of the respondent or merely the latter's farm worker.

• Jurisdiction of the MTC: Yes. The MTC had jurisdiction over the action. Jurisdiction is determined by the material allegations of the complaint and the law, irrespective of whether the plaintiff is entitled to recover all or some of the claims or reliefs sought therein. The MTC does not lose jurisdiction over an ejectment case by the simple expedient of a party raising tenancy as a defense.
• Existence of Tenancy Relationship: No. The petitioner failed to prove his claim that he had been installed by the respondent as agricultural tenant on the landholding. He relied solely on his bare claim of an agreement for a 50-50 sharing of produce, with no evidence that the respondent authorized his father to enter into such an agreement, and no evidence that he received a share of the produce.

• Jurisdiction of the MTC: The Court applied the well-entrenched principle that jurisdiction over the subject matter is determined by the material allegations of the complaint and the law, irrespective of whether the plaintiff is entitled to recover all or some of the claims or reliefs sought. Citing Basco Integrated Port Services, Inc. vs. Cyborg Leasing Corporation, the Court ruled that jurisdiction cannot be made to depend upon the defenses set up in the answer or upon a motion to dismiss. The MTC does not lose jurisdiction over an ejectment case by the simple expedient of a party raising as a defense the alleged existence of a tenancy relationship. However, it is the duty of the court to receive evidence to determine the allegations of tenancy; if, after hearing, tenancy had in fact been shown to be the real issue, the court should dismiss the case for lack of jurisdiction.

• Existence of Tenancy Relationship: The Court cited VHJ Construction and Development Corporation vs. Court of Appeals for the rule that a tenancy relationship cannot be presumed; there must be evidence to prove this allegation. The principal factor in determining whether a tenancy relationship exists is intent. The requisites of a tenancy relationship are: (1) the parties are the landowner and the tenant; (2) the subject is agricultural land; (3) there is consent by the landowner; (4) the purpose is agricultural production; (5) there is personal cultivation; and (6) there is sharing of the harvests. All these requisites are necessary to create a tenancy relationship, and the absence of one or more requisites will not make the alleged tenant a de facto tenant. The petitioner failed to prove that he had been installed by the respondent as agricultural tenant. He relied solely on his bare claim that he and the respondent, through the latter's father, Judge Felix de Guzman, had agreed for him to be the agricultural tenant, sharing the produce on a 50-50 basis net of costs of production. There was no evidence that the respondent had authorized his father to enter into such an agreement. Citing Valencia vs. Court of Appeals, the Court held that the right to hire a tenant is basically a personal right of a landowner, and for Judge de Guzman to install the petitioner as agricultural tenant, he must be specifically authorized by the respondent. The petitioner also failed to adduce evidence that he received a share of the produce. The Court found the petitioner's reliance on lists of expenses incurred by the respondent for cultivation misplaced, citing VHJ Construction and Development Corporation vs. Court of Appeals and Berenguer, Jr. vs. Court of Appeals for the rule that the fact alone of working on another's landholding does not raise a presumption of the existence of agricultural tenancy, and that to prove sharing of harvests, a receipt or any other evidence must be presented; self-serving statements are deemed inadequate.

• Determination of Jurisdiction by Material Allegations — Jurisdiction over the subject matter is determined by the material allegations of the complaint and the law, irrespective of whether the plaintiff is entitled to recover all or some of the claims or reliefs sought therein. Jurisdiction cannot be made to depend upon the defenses set up in the answer or upon a motion to dismiss. The Court applied this principle to hold that the MTC had jurisdiction over the unlawful detainer case based on the allegations of the complaint.

• Tenancy Relationship Requisites — A tenancy relationship requires: (1) the parties are the landowner and the tenant; (2) the subject is agricultural land; (3) there is consent by the landowner; (4) the purpose is agricultural production; (5) there is personal cultivation; and (6) there is sharing of the harvests. All requisites are necessary to create a tenancy relationship, and the absence of one or more requisites will not make the alleged tenant a de facto tenant. The Court applied this doctrine to find that the petitioner failed to establish a tenancy relationship because he presented no evidence of sharing of harvests or of the landowner's consent.

• Tenancy Cannot Be Presumed — A tenancy relationship cannot be presumed; there must be evidence to prove this allegation. The principal factor in determining whether a tenancy relationship exists is intent. Tenancy is not a purely factual relationship dependent on what the alleged tenant does upon the land; it is also a legal relationship. The fact alone of working on another's landholding does not raise a presumption of the existence of agricultural tenancy. The Court applied this doctrine to reject the petitioner's claim of tenancy based on his bare assertions.

• Right to Hire a Tenant is Personal to the Landowner — The right to hire a tenant is basically a personal right of a landowner. For another person to install a tenant on the landowner's behalf, that person must be specifically authorized by the landowner. The Court applied this doctrine to reject the petitioner's claim that Judge Felix de Guzman could install him as tenant without specific authorization from the respondent.

• "The well-entrenched principle is that the jurisdiction of the court over the subject matter on the existence of the action is determined by the material allegations of the complaint and the law, irrespective of whether or not the plaintiff is entitled to recover all or some of the claims or reliefs sought therein." — This passage states the controlling principle for determining jurisdiction, which is the foundation of the Court's ruling that the MTC had jurisdiction over the case.

• "The Municipal Trial Court does not lose its jurisdiction over an ejectment case by the simple expedient of a party raising as a defense therein the alleged existence of a tenancy relationship between the parties. But it is the duty of the court to receive evidence to determine the allegations of tenancy. If, after hearing, tenancy had, in fact, been shown to be the real issue, the court should dismiss the case for lack of jurisdiction." — This passage defines the proper procedure for the MTC when tenancy is raised as a defense in an ejectment case, balancing the court's jurisdiction with the DARAB's exclusive jurisdiction over agrarian disputes.

• "Indeed, a tenancy relationship cannot be presumed. There must be evidence to prove this allegation. The principal factor in determining whether a tenancy relationship exists is intent. Tenancy is not a purely factual relationship dependent on what the alleged tenant does upon the land. It is also a legal relationship." — This passage articulates the canonical formulation that tenancy cannot be presumed and requires proof of intent, which is central to the Court's rejection of the petitioner's claim.

• "The fact alone of working on another's landholding does not raise a presumption of the existence of agricultural tenancy. There must be substantial evidence on record adequate enough to prove the element of sharing." — This passage emphasizes the necessity of proving the sharing element with substantial evidence, not mere self-serving statements, which was the decisive ground for denying the petition.

• Cruz vs. Torres, 316 SCRA 193 (1999) — Cited as authority for the principle that jurisdiction over the subject matter is determined by the material allegations of the complaint and the law.
• Basco Integrated Port Services, Inc. vs. Cyborg Leasing Corporation, 317 SCRA 327 (1999) — Cited for the rule that jurisdiction cannot be made to depend upon the defenses set up in the answer or upon a motion to dismiss.
• Boleyley vs. Villanueva, 314 SCRA 364 (1999) — Cited in support of the principle that jurisdiction is determined by the allegations of the complaint, not the defenses.
• Cervantes vs. Court of Appeals, 263 SCRA 323 (1996) — Cited for the rule that once jurisdiction is vested, it is retained up to the end of litigation, and that the court should dismiss the case for lack of jurisdiction if tenancy is shown to be the real issue.
• Onquit vs. Binamira-Parcia, 297 SCRA 354 (1998) — Cited for the rule that the MTC does not lose jurisdiction over an ejectment case by the simple expedient of a party raising tenancy as a defense, and that the court has the duty to receive evidence to determine the allegations of tenancy.
• Isidro vs. Court of Appeals, 228 SCRA 503 (1993) — Cited in support of the rule that the court should dismiss the case for lack of jurisdiction if tenancy is shown to be the real issue.
• VHJ Construction and Development Corporation vs. Court of Appeals, G.R. No. 128534, August 13, 2004 — Controlling precedent cited for the requisites of a tenancy relationship and the rule that tenancy cannot be presumed; also cited for the rule that self-serving statements regarding tenancy relations could not establish the claimed relationship.
• Chico vs. Court of Appeals — Cited within VHJ Construction for the proposition that the de jure leasehold or tenancy relationship is the terra firma for security of tenure, and that the mutual will of the parties should be primordial.
• Valencia vs. Court of Appeals, 406 Phil. 666 (2003) — Cited for the rule that the right to hire a tenant is basically a personal right of a landowner, requiring specific authorization for another to install a tenant.
• Berenguer, Jr. vs. Court of Appeals, 164 SCRA 431 (1988) — Cited within VHJ Construction for the rule that the fact alone of working on another's landholding does not raise a presumption of agricultural tenancy, and that proof of sharing is essential.

• R.A. 6657 (Comprehensive Agrarian Reform Law) — The petitioner argued that the CA erred in not applying this law, as applied by the RTC, considering that he had met the six requirements for a tenancy relationship. The Court implicitly rejected this argument by finding that the petitioner failed to prove the requisites of tenancy.
• Rules on Unlawful Detainer (jurisdictional framework) — The Court applied the principle that jurisdiction over ejectment cases is determined by the material allegations of the complaint, and that the MTC retains jurisdiction unless tenancy is proven to be the real issue.

Puno, Austria-Martinez (on official leave), Tinga, and Chico-Nazario, JJ., concurred.

N/A — No dissenting opinions are noted in the decision.