ALMAZAN VS. BACOLOD, G.R. NO. 227529 (16 JUNE 2021):
AFFIRMING THE OF JURISDICTION OF THE COURTS IN QUIETING OF TITLE OVER DARAB WHEN NO CLEAR TENANCY RELATIONSHIP
First Part of a Two-Part Series
“Jurisdiction over the subject matter is determined by the allegations in the complaint. In line with this, for the DARAB to acquire jurisdiction over the case, there must be clear proof of a tenancy relationship between the parties. Likewise, only a de jure tenant may enforce his/her right to security of tenure against the landowner.”
This case is not uncommon wherein the legitimate and registered owner of a parcel of land is usually the one filing a case for quieting of title and/or recover possession of a property from persons claiming to be tenants of the previous owner or predecessor-in-interest. In this case, petitioner Eduviges Almazan is among the registered owners of a 5,865 square meter parcel of land located in Barangay Dita/Malilit, Sta. Rosa City, Laguna, covered by Transfer Certificate of Title (TCT) No. T-060-2012008993 of the Registry of Deeds of Calamba, Laguna. He and his co-owners inherited the subject property from their grandfather Agapito Almazan (“Agapito”).
Sometime in 2010, petitioner visited the subject property and was surprised that respondents Perla Bacolod, Dulce Bacolod, Irma Bacolod, and Belen Bacolod (collectively as “respondents”) are occupying the subject property. He demanded them to vacate the land, but the respondents refused arguing that they are agricultural tenants showing Decisions from the Provincial Agrarian Reform Adjudicator (PARAD) dated 03 July 2000 and Department of Agrarian Reform Adjudication Board (DARAB) dated 11 October 2007. Petitioner denied the existence of any tenurial relationship between him and his co-owners and the respondents and that their predecessor-in-interest, their grandfather Agapito, had no known tenant.
Petitioner then filed a Complaint before Regional Trial Court of Biňan City, Laguna for Quieting of Title, Accion Reivindicatoria and Damages arguing that the PARAD and DARAB Decisions create a cloud on their Torrens title. Petitioner argues that they are not bound of the PARAD and DARAB Decisions since they are not parties thereto and such are against Arturo, Norberto, Virginia, Ruben, Manual and Bayani, all surnamed Erana (collectively as the “Eranas”) whom petitioner does not know and has no relationship whatsoever.
Respondents filed an Answer with Compulsory Counterclaim with Prayer for the Hearing of Affirmative Defenses/Motion to Dismiss. The trial court denied respondent’s Motion to Dismiss, hence, the latter filed a Petition for Certiorari before the Court of Appeals. The Court of Appeals granted respondents Petition and reversed the ruling of the trial court ruling that the tenancy of the respondents is attached to the land and that petitioner, and his co-owners are merely subrogated to the shoes of the previous owner of the property.
Petitioner filed a Petition for Review under Rule 45 of the Rules of Court before the Supreme Court. The Supreme Court reversed the ruling of the Court of Appeals. Citing Green Acres Holdings, Inc. vs. Cabral, et al., 710 Phil. 235 (2013), the Supreme Court held that the PARAD and DARAB Decisions may be considered as “instruments” or “records” which create cloud on the Torrens title of the petitioner. Hence, the trial court has jurisdiction over the case for Quieting of Title. The Court also restated the delineation of the jurisdiction of the courts and DARAB, to wit:
“The law and jurisprudence have delineated the powers of the DARAB and the regular courts, by limiting the farmer’s jurisdiction to the resolution of agrarian disputes. Specifically, an agrarian dispute is any controversy that relates to tenurial arrangements, be it a leasehold, tenancy, stewardship or otherwise, involving lands devoted to agriculture. It also includes cases relating to farm workers’ associations or representations of persons in negotiating, fixing, maintaining, changing or seeking to arrange terms or conditions of such tenurial arrangements. Likewise, it also involves disputes relating to the 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
Juxtaposing the requisites with the allegations in the Complaint, it is patent that the DARAB has no jurisdiction over the case.”
In the case at bar, the Court found no landlord-tenant relationship between the petitioner and the respondents. First, petitioner was able to present a Certification from the Municipal Agrarian Reform Office (MARO) dated 05 November 2007 that Agapito had no registered tenants. Hence, there could have been no nexus between Agapito, the predecessor-in-interest of the petitioner and his co-owners, and the Eranas against whom the respondents obtained the PARAD and DARAB Decisions. Second, there being no relationship between the petitioner, his co-owners, and predecessors-in-interest with the respondents, then obviously, the element of consent is likewise wanting. Third, respondents admitted that there is no sharing of harvests between the parties since the respondents remit their harvests to Eranas, and later to Erlinda Jaurigue-Alcabasa and Rosita Jaurigue-Aquino, and not to the petitioner, any of his co-owners, or a predecessor-in-interest. (To be continued on the next part)