Sunday, July 15, 2012

" Agrarian Dispute" refers to any controversy relating to tenurial arrangements, whether leasehold, tenancy, stewardship or otherwise, over lands devoted to agriculture, including disputes concerning farmworkers associations or representation of persons in negotiating, fixing, maintaining, changing or seeking to arrange terms or conditions of such tenurial arrangements. It includes any controversy relating to compensation of lands acquired under RA 6657 and other terms and conditions of transfer of ownership from landowners to farmworkers, 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. - G.R. Nos. 155322-29

G.R. Nos. 155322-29

"x x x.



This Court’s Ruling on the Main Issue

This case properly falls within the jurisdiction of the RTC.

Rule II, Section 1 of the Revised Rules of Procedure of the DARAB provides:

Section 1. Primary, Original and Appellate Jurisdiction. ---The Agrarian Reform Adjudication Board shall have primary jurisdiction, both original and appellate, to determine and adjudicate all agrarian disputes, cases, controversies, and matters or incidents involving the implementation of the Comprehensive Agrarian Reform Program under Republic Act No. 6657, Executive Order Nos. 229, 228 and 129-A, Republic Act No. 3844 as amended by Republic Act No. 6389, Presidential Decree No. 27 and other agrarian laws and their implementing rules and regulations.


Under Section 3(d) of Republic Act No. 6657 an “agrarian dispute” is defined as follows:

(d) Agrarian Dispute refers to any controversy relating to tenurial arrangements, whether leasehold, tenancy, stewardship or otherwise, over lands devoted to agriculture, including disputes concerning farmworkers associations or representation of persons in negotiating, fixing, maintaining, changing or seeking to arrange terms or conditions of such tenurial arrangements.

It includes any controversy relating to compensation of lands acquired under this Act and other terms and conditions of transfer of ownership from landowners to farmworkers, 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.


          This Court agrees with the BCDA for this case to fall within the ambit of DARAB’s jurisdiction, the issue must be one that involves an agrarian dispute, which is not attendant in the instant case.[41]

It is a basic rule that jurisdiction is determined by the allegations in the complaint. [42]  The BCDA’s complaints did not contain any allegation that would, even in the slightest, imply that the issue to be resolved in this case involved an agrarian dispute.  In the action filed by the BCDA, the issue to be resolved was who between the BCDA and the private respondents and their purported predecessors-in-interest, have a valid title over the subject properties in light of the relevant facts and applicable laws.  The case thus involves a controversy relating to the ownership of the subject properties, which is beyond the scope of the phrase “agrarian dispute.”[43] 

The RTC, therefore, gravely erred when it dismissed the complaints on the grounds that they were prematurely filed.  The action filed by the BCDA was cognizable by regular courts.
 x x x."