MARTIN HEIDEGGER:

On December 28, 2000, Yupangco Cotton Mills, Inc. filed with the RTC a complaint for Recovery of Ownership and Possession, Violations of R.A. Nos. 6657 and 3844 as amended, Cancellation of Title, Reconveyance and Damages with Prayer for the Issuance of Preliminary Mandatory Injunction and/or Temporary Restraining Order against Buenavista Yupangco Agrarian Reform Beneficiaries Association, Inc., the DAR and the Land Bank of the Philippines. DAR filed a Motion to Dismiss on the grounds that Yupangco’s causes of action were not within the jurisdiction of the RTC. RTC denied the motion. On appeal to the CA, the appellate court sustained the RTC.

Issue:

Whether or not the RTC has jurisdiction over the case Held:

The complaint in the petition at bar seeks for the RTC to cancel Certificates of Land Ownership Awards issued to the beneficiaries and the Transfer Certificates of Title issued pursuant thereto. These are reliefs which the RTC cannot grant, since the complaint essentially prays for the annulment of the coverage of the disputed property within the CARP, which is but an incident involving the implementation of the CARP. These are matters relating to terms and conditions of transfer of ownership from landlord to agrarian reform beneficiaries over which DARAB has primary and exclusive original jurisdiction. If the issues between the parties are intertwined with the resolution of an issue within the exclusive jurisdiction of the DARAB, such dispute must be addressed and resolved by the DARAB.

36

Philippine Veterans Bank v CA Facts:

Petitioner Philippine Veterans Bank owned four parcels of land in Tagum, Davao. The lands were taken by the DAR for distribution to landless farmers pursuant to R.A. No. 6657. Dissatisfied with the valuation of the land made by respondents Land Bank of the Philippines and the DARAB, petitioner filed a petition for a determination of the just compensation for its property with the RTC which dismissed the petition on the ground that it was filed beyond the 15-day reglementary period for filing appeals from the orders of the DARAB.

Issue:

Whether or not the petitioner can still appeal after the 15-day period for filing appeals Held:

Rule XIII, Section 11 of the DARAB Rules of Procedure provides that “the decision of the Adjudicator on land valuation and preliminary determination and payment of just compensation shall not be appealable to the Board but shall be brought directly to the Regional Trial Courts designated as Special Agrarian Courts within fifteen (15) days from receipt of the notice thereof.” The petition in the RTC was filed beyond the 15-day period provided in Rule XIII, Section 11 of the Rules of Procedure of the DARAB, the trial court correctly dismissed the case.

37

Samahang Magbubukid ng Kapdula Inc. v CA Facts:

The members of petitioner Samahang Magbubukid Ng Kapdula, Inc. were the tenants on the two parcels of land formerly owned by Macario Aro. When Mr. Aro sold the said parcels of land to Arrow Head Golf Club, Inc., the members of petitioner were evicted. The parcels of land were later leased to the spouses, Ruben Rodriguez and Gloria Bugagao and were then developed into a sugarcane plantation, with private respondents as the regular farmworkers. The same property was acquired by the Philippine National Bank at a Sheriff’s auction sale. The ownership of subject parcels of land was later transferred to the Asset Privatization Trust which conveyed the same to the Republic of the Philippines. On March 26, 1991, in furtherance of its objective of instituting agrarian reform in the country, the DAR issued Certificate of Land Ownership for the said parcels of land in favour of the petitioner. Private respondents filed a petition for certiorari on CA which ordered the respondent DAR to conduct a hearing, with due notice to the herein petitioners, to determine the rightful beneficiaries of the subject parcels of land in accordance with R.A. No. 6657.

Issue:

Whether or not there was a need for the private respondents to exhaust administrative remedies before filing their petition for certiorari with the Court of Appeals

Held:

Time and again, the Court has ruled that in cases of denial of due process, exhaustion of available administrative remedies is unnecessary. Records show that the letter which was supposed to be the notice to the private respondents regarding the inclusion of subject properties in the CARP was ineffective. There is thus a need for further hearings to determine the beneficiaries of subject parcels of land. In such hearings, the private respondents, who were deprived of an opportunity to be heard before the DAR, should participate.

38

Greenfield Realty Corporation v Cardama Facts:

Private respondents filed with the Provincial Adjudicator of Sta. Cruz, Laguna against Independent Realty Corporation, among others. Respondents claimed to have already been issued their respective Certificates of Land Transfer pursuant to Presidential Decree No. 27 which took effect on October 21, 1972, thus subject landholdings can no longer be covered by the CARP law. Respondents also claimed to have succeeded their father who died on January 9, 1989 in the latter’s tenancy rights, and should be declared now as leasehold tenants and actual tillers of the subject irrigated riceland. Judgment was rendered in favour of the private respondents by the Provincial Adjudicator. On appeal to the DARAB, it was declared that the respondents are not bona fide tenant of the subject property. When the case was brought to the CA, the decision of the Provincial Adjudicator was reinstated.

Issue:

Whether or not the decision of the DARAB is based on substantial evidence and thus should become final and conclusive upon the court

Held:

Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. Even if we consider that the evidence presented is relevant, they are not adequate to support the conclusion reached by the DARAB. On the other hand, the records of the case are replete with relevant evidences which are adequate to support the conclusion that Hermogenes Cardama is the bona fide tenant of the subject property. Thus, the evidences on which DARAB based its decision are not relevant and adequate to support its conclusion.

39 Bernarte v CA Facts:

On October 5, 1989, Estrella Arastia filed a complaint for violation of Section 73 (b) of RA 6657 before the RTC in its capacity as a Special Agrarian Court. The complaint alleged that petitioners illegally intruded into the land of Arastia, burned the existing sugarcane plants and started to cultivate small portions thereof. Petitioner moved for the dismissal of the complaint on the ground that the trial court had no jurisdiction as it was the DARAB, pursuant to Section 50 of RA 6657, which had jurisdiction over the case. The motion was dismissed by the RTC. Meanwhile a writ of preliminary injunction to enjoin Arastia from preventing their re-entry and re-occupation of the landholdings pending the resolution of the case was also obtained by petitioners from DARAB. When the petitioners were arrested by the police officers for their refusal to leave the property, and was thereafter criminally charged, they asserted that the preliminary injunction obtained by them in the DARAB was the one valid since the trial court has no jurisdiction over the case.

Issue:

Whether or not the RTC has jurisdiction over the case Held:

Jurisdiction over the subject-matter is determined upon the allegations made in the complaint. Petitioner’s raising the issue of jurisdiction in their answer to the complaint did not automatically divest the lower court of jurisdiction over agrarian case filed by Arastia. The court had to continue exercising authority to hear the evidence for the purpose of determining whether or not it had jurisdiction over the case. It should be pointed out that in filing the case, Estrella Arastia was merely ejecting petitioners from the land on the ground that no tenancy relationship existed between them. However, her invocation of Sec. 73 (b) of Republic Act No. 6657 which considers as a prohibited act “forcible entry or illegal detainer by persons who are not qualified beneficiaries under this Act to avail themselves of the rights and benefits of the Agrarian Reform Program,” obviously led the court to docket the case as Agrarian Case No. 2000 and assume jurisdiction over it as a special agrarian court.

40

Land Bank v De Leon Facts:

Respondent spouses Arlene and Bernardo de Leon filed a petition to fix the just compensation of a parcel of land before the RTC of Tarlac acting as a Special Agrarian Court. On December 19, 1997, the agrarian court rendered summary judgment fixing the compensation of the subject property. The DAR and LBP both filed separate appeals using different modes. DAR filed a petition for review while LBP interposed an ordinary appeal by filing a notice of appeal. The appeal by the DAR was given due course, while that of the LBP was dismissed on the ground that LBP availed of the wrong mode of appeal.

Issue:

Whether or not an ordinary appeal was the proper mode to appeal the decision of the RTC regarding just compensation

Held:

On account of the absence of jurisprudence interpreting Sections 60 and 61 of RA 6657 regarding the proper way to appeal decisions of Special Agrarian Courts as well as the conflicting decisions of the Court of Appeals thereon, LBP cannot be blamed for availing of the wrong mode. Based on its own interpretation and reliance on a ruling of the CA regarding the same issue, LBP acted on the mistaken belief that an ordinary appeal is the appropriate manner to question decisions of Special Agrarian Courts. While the Court holds that petition for review is the proper mode of appeal from judgments of Special Agrarian Courts, and such is a rule of procedure which affects substantive rights, it should not be applied to the case of LBP since this case was still pending when said doctrine was decreed.

41

Laurel vs. Garcia Facts:

These are two petitions for prohibition seeking to enjoin respondents, their representatives and agents from proceeding with the bidding for the sale of the 3,179 square meters of land at 306 Roppongi, 5-Chome Minato-ku Tokyo, Japan scheduled on February 21, 1990 or the Roppongi property acquired by the Government from Japan. Laurel states that the Roppongi property is classified as one of public dominion, and not of private ownership under Article 420 of the Civil Code. He states that being one of public dominion, no ownership by anyone can attach to it, not even by the State. Hence, it cannot be appropriated, as it is outside the commerce of man. The respondents refute the petitioner's contention by saying that the subject property has ceased to become property of public dominion. It has become patrimonial property because it has not been used for public service or for diplomatic purposes for over thirteen years now and because the intention by the Executive Department and the Congress to convert it to private use has been manifested by overt acts, one of which is the enactment by the Congress RA 6657 which contains a provision stating that funds may be taken from the sale of Philippine properties in foreign countries

Issue:

Whether or not the Roponggi property can be alienated and sold for funding purposes of the CARP in accordance with Section 63[C] of RA6657?

Held:

No. Section 63 (c) of Rep. Act No. 6657 which provides as one of the sources of funds for its implementation, the proceeds of the disposition of the properties of the Government in foreign countries, did not withdraw the Roppongi property from being classified as one of public dominion when it mentions Philippine properties abroad. Section 63 (c) refers to properties which are alienable and not to those reserved for public use or service. Rep Act No. 6657, therefore, does not authorize the Executive Department to sell the Roppongi property. It merely enumerates possible sources of future funding to augment the Agrarian Reform Fund created under Executive Order No. 299. Obviously any property outside of the commerce of man cannot be tapped as a source of funds.

42 Rovillos v CA Facts:

Sometime in 1971, petitioner's predecessor started tilling and cultivating a portion of private respondent's land under a share-crop agreement. On December 30, 1979, petitioner and the private respondent entered into a contract which stipulated that the former was to be contracted as a farm laborer or helper responsible for the cultivation of two hectares of the four hectare land. When petitioner no longer cultivated the land in question in his capacity as a farm laborer but as a tenant, with the corresponding right to exclude the private respondent from the land, private respondent demanded from the petitioner to desist from further cultivation of the said land. These demands proved futile. Private respondent then filed a complaint against the petitioner for Recovery of Possession with Damages with Motion for Issuance of Writ of Preliminary Injunction. On February 20, 1991, the trial court rendered its decision finding that petitioner was not a tenant but a mere farm helper or laborer of the private respondent. The decision of the RTC was affirmed by CA.

Issue:

Whether or not RA 6657 has repealed the provisions of PD 27 Held:

The Supreme Court pointed out that the land in question is covered by Presidential Decree No. 27, which, incidentally has not yet been repealed by Republic Act No. 6657. The provisions of PD 27 shall have a suppletory effect.

43 Reyes v Reyes Facts:

On April 22, 1991, Dionisia Reyes filed a complaint for reinstatement with DARAB against private respondents, her four younger brothers. She alleged that her father, the late Felizardo Reyes, was the tenant of a two-hectare agricultural lot owned by Marciano Castro. After her father’s death, she and Marciano Castro executed a leasehold contract naming her as the agricultural lessee of the property. However, sometime before the start of the planting of the dry season crop in 1989, respondents forcibly entered the area and occupied a one-hectare portion of the property. They claimed to be the tenants thereof. Respondents then paid rent to the Castros’ overseer and continued to occupy half of the property to petitioner’s damage and prejudice. Respondents denied Dionisia’s claim that she was the bona fide leasehold tenant. They claimed that they inherited the lease rights to the property from their deceased father. They likewise averred that they were the ones actually cultivating the portion occupied by them. Hence, petitioner’s claim to be the lawful agricultural lessee had no basis, either in fact or in law. Issues:

Whether or not the RA 6657 has suppletory character with that of RA 3844 insofar as the determination of leasehold agreement is concern?

Held:

The present dispute involves an agricultural leasehold. The governing law is R.A. No. 3844, which, except for Section 35 thereof, was not specifically repealed by the passage of the R.A. No. 6657, but was intended to have suppletory effect to the latter law. Under R.A. 3844, two modes are provided for in the establishment of an agricultural leasehold relation: (1) by operation of law in accordance with Section 4 of the said act or (2) by oral or written agreement, either express or implied. By operation of law simply means the abolition of the agricultural share tenancy system and the conversion of share tenancy relations into leasehold relations. The other method is the agricultural leasehold contract, which may either be oral or in writing. In the instant case, it is not disputed that an agricultural leasehold contract was entered into between petitioner and Ramon Castro.