ANTONIO R. CRUZ AND LORETO TERESITA CRUZ-DIMAYACYAC, AS HEIRS OF THE LATE SPOUSES DR. PROGEDIO R. CRUZ AND TERESA REYES, PETITIONERS, VS. CARLING CERVANTES AND CELIA CERVANTES SANTOS AND ALL PERSONS CLAIMING RIGHTS UNDER THEM, RESPONDENTS.
- G.R. Number: G.R. No. 244433
- Promulgated: 2022-04-19
- Ponente: ROSARIO, J.
Doctrine
## Facts of the Case Petitioners Antonio R. Cruz and Loreto Teresita Cruz-Dimayacyac, as heirs of the late spouses Progedio R. Cruz and Teresa Reyes, filed a complaint for unlawful detainer against respondents Carling Cervantes and Celia Cervantes Santos. Petitioners alleged that respondents' father, Isidro, was allowed to temporarily occupy a portion of their land in Plaridel, Bulacan, in 1960, on the condition that he and his family would vacate upon demand. After Isidro and the spouses Cruz passed away, respondents continued to occupy the land under the same condition. In 2015, petitioners demanded that respondents vacate the property, but they refused. Respondents countered that the MTC lacked jurisdiction because the subject property was agricultural land, and they were tenants who succeeded their father, Isidro. They claimed that Isidro was a tenant of the spouses Cruz from 1965 to 2005, cultivating the land and paying compensation. They presented a tally sheet from a rice mill naming Teresa Reyes Vda. de Cruz as "Name" and Isidro Cervantes as "Kasama," and a handwritten receipt for "Buwis sa Bakuran" paid by "Sidro Cervantes." The MTC referred the case to the Provincial Agrarian Reform Office (PARO), which certified the case as agrarian in nature and recommended its dismissal for lack of jurisdiction. The MTC, RTC, and CA all affirmed the dismissal based on this PARO certification. ## Issues 1. Did the MTC, RTC, and CA err in affirming the dismissal of the complaint for unlawful detainer on the ground of lack of jurisdiction, based solely on the PARO certification that the action involves an agrarian dispute? 2. Did the PARO certification comply with the procedural requirements of DAR Administrative Order No. 03-11? 3. Did the respondents present sufficient evidence to establish the existence of an agricultural tenancy relationship? ## Decision / Rationale **Issue 1:** The Supreme Court ruled in the **negative** regarding the referral of the case to the PARO, stating that the MTC did not err in making the referral itself. However, the Court ruled in the **affirmative** that the MTC erred in relying solely on the PARO's certification to dismiss the complaint for lack of jurisdiction, as the certification failed to comply with procedural requirements and the alleged tenancy relationship was not sufficiently established. **Issue 2:** The Supreme Court held that the **PARO certification failed to comply** with the procedures outlined in **DAR AO No. 03-11**. Specifically, the certification did not state the findings of fact upon which the determination by the PARO was based. This lack of factual basis prevented the courts from ascertaining the evidence from which the PARO's findings were drawn. While courts are bound to comply with the referral mechanism, they are not bound to accept a recommendation that violates established procedures and requirements. **Issue 3:** The Supreme Court found that **respondents failed to discharge the burden of proving** that their predecessor-in-interest, Isidro, was an agricultural tenant of the spouses Cruz. The documents presented (tally sheet identifying Isidro as "Kasama" and a handwritten receipt for "Buwis sa Bakuran") did not satisfactorily show that the spouses Cruz consented to an alleged tenancy relationship or agreed to a share in the harvests. The Court emphasized that occupancy and cultivation alone do not create a de jure tenancy; independent and concrete evidence of personal cultivation, sharing of harvest, and landowner consent is necessary. The fact of receiving produce, without an agreed system of sharing, does not automatically create a tenancy. Therefore, no agricultural tenancy relationship was established, and the MTC has jurisdiction over the unlawful detainer case. ## Doctrines - **Jurisdiction over Agrarian Disputes (Section 50-A of RA No. 6657, as amended by RA No. 9700):** If there is an allegation from any of the parties that a case is agrarian in nature and one…
Keywords
RA 6657, RA 9700 Section 50-A, Rules of Court Rule 45, Doctrine of Primary Jurisdiction, Unlawful Detainer, Agrarian Dispute, Jurisdiction, Tenancy Relationship, Agricultural Land, Ejectment, Certiorari, De Jure Tenant, Substantial Evidence, Prejudicial Question, Petition granted, Case remanded, MTC dismissal reversed, CA decision reversed, agrarian, jurisdiction