TL;DR

The Supreme Court clarified that while lower courts must refer cases to the Department of Agrarian Reform (DAR) when agrarian disputes are alleged, they are not bound to blindly accept the DAR’s certification. In Cruz v. Cervantes, the Court ruled that certifications must detail the factual basis for their conclusions. If a certification lacks this detail or misapplies evidence, courts must independently review the case to determine proper jurisdiction. This ensures that ordinary ejectment cases are not improperly dismissed as agrarian disputes, protecting landowners’ rights to pursue eviction in regular courts when tenancy is not sufficiently proven.

Tenant or Trespasser? Scrutinizing DAR Certifications in Ejectment Cases

In Antonio R. Cruz and Loreto Teresita Cruz-Dimayacyac v. Carling Cervantes and Celia Cervantes Santos, the central question revolved around whether a simple ejectment case was actually an agrarian dispute, requiring the specialized jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB), or if it remained within the purview of the Municipal Trial Court (MTC). This case highlights the critical balance between respecting the DAR’s expertise in agrarian matters and the judiciary’s duty to ensure procedural and jurisdictional accuracy.

The petitioners, heirs of Spouses Cruz, filed an unlawful detainer case against the respondents, who were occupying a portion of the petitioners’ land. The respondents claimed to be tenants, asserting an agrarian dispute and thus, the jurisdiction of the DARAB. The MTC, relying on a certification from the Provincial Agrarian Reform Office (PARO) that the case was agrarian in nature, dismissed the case for lack of jurisdiction. This dismissal was upheld by the Regional Trial Court (RTC) and the Court of Appeals (CA).

However, the Supreme Court reversed these decisions, emphasizing that while the referral to the PARO was initially correct due to the respondents’ tenancy claim, the MTC erred in automatically adopting the PARO’s certification. The Court underscored that the PARO’s certification was deficient because it failed to articulate the factual basis for its determination. Department of Agrarian Reform Administrative Order (DAR AO) No. 03-11 mandates that such certifications must include the findings of fact supporting the conclusion of an agrarian dispute.

The Supreme Court referenced Section 50-A of Republic Act No. 6657, as amended by Republic Act No. 9700, which mandates automatic referral to the DAR if there’s an allegation of an agrarian dispute and one party is a farmer, farmworker, or tenant. However, the Court in Chailese Development Co., Inc. v. Dizon clarified that while a mere allegation suffices for the ‘agrarian nature’ of the case, proof is needed to establish the status of farmer, farmworker, or tenant. In this case, the respondents presented a tally sheet and a receipt as evidence of tenancy. However, the Court found these insufficient to prove a tenancy relationship, particularly the essential elements of consent from the landowner and a clear sharing agreement.

SECTION 50-A. Exclusive Jurisdiction on Agrarian Dispute. — No court or prosecutor’s office shall take cognizance of cases pertaining to the implementation of the CARP… If there is an allegation from any of the parties that the case is agrarian in nature and one of the parties is a farmer, farmworker, or tenant, the case shall be automatically referred by the judge or the prosecutor to the DAR which shall determine and certify within fifteen (15) days from referral whether an agrarian dispute exists…

The Court highlighted that mere occupation and cultivation do not automatically create tenancy. Crucially, the Court reiterated the indispensable elements of a tenancy relationship:

1. The parties are landowner and tenant/agricultural lessee.
2. The subject matter is agricultural land.
3. Consent exists between parties for the relationship.
4. The purpose is agricultural production.
5. Personal cultivation by the tenant/lessee.
6. Harvest sharing between landowner and tenant/lessee.

Absence of even one element negates de jure tenancy. The Court found that the respondents failed to provide substantial evidence of consent and harvest sharing, critical components for establishing tenancy. The tally sheet and receipt lacked signatures or acknowledgment from the landowners, Spouses Cruz, and did not conclusively prove a sharing agreement. Citing Rivera v. Santiago, the Court noted that mere receipt of produce, without a clear sharing system, does not automatically establish tenancy.

Therefore, the Supreme Court concluded that the lower courts erred in dismissing the unlawful detainer case based solely on the deficient PARO certification. The Court emphasized that while administrative findings are generally respected, courts must independently assess jurisdiction, especially when certifications lack factual basis or misinterpret evidence. The case was remanded to the MTC for further proceedings, affirming the MTC’s jurisdiction over the unlawful detainer case due to the absence of a proven agrarian dispute.

FAQs

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Cruz v. Cervantes, G.R No. 244433, April 19, 2022