Assignement 3 - 23 Fajardo v. Flores

Fajardo v.
Flores
Facts: Leopoldo Delos Reyes owned a parcel of land in Bulacan. He allowed
petitioner Jesus Fajardo to cultivate it and have an equal share in the net harvest.
Thereafter, their relationship was converted to a leasehold tenancy. Subsequently,
petitioner was able to acquire a right to a home lot and a right to its exclusive
possession pursuant to the Agricultural Land Reform Code. Leopoldo also allowed
petitioner to erect a house for his family on the stony part of the land which is the
subject of the controversy.
When Leopoldo died, his daughter, herein respondent Anita Flores inherited the said
land. Petitioner and respondent consequently executed an agreement, denominated
as Kasunduan sa Paghahati ng Lupa at Pagtatalaga ng daan ukol sa magkabilang
panig followed by another agreement Kasunduan sa Hatian sa Lupa. However,
both parties had a conflict of claims in the interpretation of such kasunduan. They
were advised by the DAR legal officer to ventilate their claims with the DARAB.
Consequently, respondent filed a complaint for ejectment with the MTC against the
petitioner on the ground that the latter refused to surrender the stony portion of
land which is the lot in question. Petitioners filed a Motion to Dismiss, alleging that
lot was an agricultural land, therefore MTC had no jurisdiction over the case,
considering that the dispute between the parties, regarding the Kasunduan, was
referred to the DARAB; and that the assumption by the DARAB of jurisdiction over
the controversy involving the lot in question therefore precluded the MTC from
exercising jurisdiction over the case.
MTC ruled in favour of the respondent. On appeal, the Regional Trial Court affirmed
the MTC Decision in toto. However, on motion for reconsideration, the RTC reversed
its decision pm the ground the issue involved appeared to be an agrarian dispute,
which fell within the contemplation of Republic Act (R.A.) No. 6657, otherwise known
as the Comprehensive Agrarian Reform Law of 1988, and thus ordered the dismissal
of the case for lack of jurisdiction.
A petition for review was then filed by respondents with the CA to annul the Order of
the RTC.
CA rendered the assailed decision, which reinstated the MTC decision. It disagreed
with the findings of the RTC that the lot in controversy was agricultural in nature,
but one which was non- agricultural in character. It explained that, on the strength
of the two instruments, the parties made a partition and divided the agricultural
portion of the lot equally among themselves. By virtue of said division, the parties
effectively severed and terminated the agricultural leasehold/tenancy relationship
between them; thus, there was no longer any agrarian dispute to speak of. Fajardo
had already acquired the benefits under the Comprehensive Agrarian Reform Law
when one-half of the agricultural portion of Lot No. 2351 was allotted to him.
Petitioners cannot, therefore, be allowed to continue possession of a part of the
stony portion, which was not included in the land he was cultivating.
Issue: Whether it is MTC or the DARAB which has jurisdiction over the case.
Ruling: In the case at bar, petitioners claim that the tenancy relationship has
been terminated by the Kasulatan is of no moment. As long as the subject matter
of the dispute is the legality of the termination of the relationship, or if the dispute
originates from such relationship, the case is cognizable by the DAR, through the
DARAB. The severance of the tenurial arrangement will not render the action
beyond the ambit of an agrarian dispute.
Furthermore, the records disclose that the dispute between the parties, regarding
the interpretation of the Kasunduan, was, in fact, raised and referred to the DAR,
which in turn referred the case to the DARAB. In view of the foregoing, the court
reiterate Hilario v. Prudente, that:
The doctrine of primary jurisdiction precludes the courts from resolving a
controversy over which jurisdiction has initially been lodged with an administrative
body of special competence For agrarian reform cases, jurisdiction is vested in the
Department of Agrarian Reform (DAR); more specifically, in the Department of
Agrarian Reform Adjudication Board (DARAB).

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