The Supreme Court (SC) has remanded to the lower court for further proceedings a case involving a land in Laguna subjected to agrarian reform even if the landowner and supposed tenant denied having ever known each other, much less having a tenancy agreement.
In a 16-page decision recently made available online, the high tribunal reversed and set aside a Court of Appeals (CA) ruling and remanded the case to the regional trial court (RTC) for “a full resolution of the issues” after the court noted that “both parties admitted that they have no relationship with each other whatsoever”.
The court emphasized there “must be clear proof of a tenancy relationship between the parties” before the Department of Agrarian Reform Adjudication Board (DARAB) can assume jurisdiction.
The case involves petitioner Eduviges Almazan, one of the registered owners of a 5,865-square-meter land located in Barangay Dita and Barangay Malitlit in the City of Santa Rosa, having inherited it, along with his co-owners, from their grandfather, Agapito Almazan.
In a visit to the property in 2010, Eduviges was surprised to discover occupants on their land and demanded that they vacate it.
Named as respondents were Perla, Dulce, Irma, and Belen Bacolod.
The Bacolods refused to vacate the property, claiming they are agricultural tenants under decisions rendered in 2007 by the DARAB.
The DARAB decision was for individuals surnamed Erana, with whom Almazan claimed he had no relations.
Almazan subsequently filed a complaint before the Biñan City RTC against the Bacolods for damages.
The Bacolods, however, argued the case should be taken up before the DARAB and questioned the jurisdiction of the RTC before the CA, which ruled in their favor.
The Bacolods also claimed that Almazan is “feigning ignorance about their status as tenants” and accused the petitioner’s lawyer, Melvin Mane, of intimidation and harassment.
In upholding RTC’s jurisdiction, the SC said DARAB’s jurisdiction is limited to agrarian dispute and an essential requisite would be “the existence of a tenancy relationship between the parties”.
A tenancy relationship cannot be presumed, said the court.
For tenancy relationship to exist, the following essential requisites must be present: the parties are the landowner and the tenant; the subject matter is agricultural land; consent between the parties; agricultural production; personal cultivation by the tenant; and sharing of the harvests between the parties.
“The agrarian laws that grant the DARAB exclusive jurisdiction to rule on agrarian disputes, as well as those which provide the landless farmers security of tenure and protect them against eviction from the landholdings, are without a doubt, laudable. However, these rights, sacred as they are, may not be enforced against strangers or those who have not consented to the relationship, personally or through their predecessors,” the tribunal ruled.
Source: Philippines News Agency
