DY BUNCIO V. RAMOS [G.R. No. 206120, March 23, 2022]

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DY BUNCIO V. RAMOS

G.R. No. 206120, March 23, 2022

SECOND DIVISION, HERNANDO J.

 

Certiorari, Agrarian Law, RA 6657, Jurisdiction, Agrarian Dispute, Tenancy, Relationship 

DOCTRINE: This principle emphasizes that issues related to agrarian disputes, particularly those involving tenancy arrangements and agricultural lands, should be primarily addressed by the DAR and its adjudicative bodies.

 

The case involves a complaint for Accion Reinvindicatoria and Damages filed by Buncio with the Regional Trial Court (RTC) of Cabanatuan City, alleging her ownership of a parcel of land and seeking to remove respondents Leontina and Fernando Ramos from the property. Respondents argued that the RTC lacked jurisdiction due to a leasehold agreement, and a preliminary determination was made regarding the existence of tenancy. The RTC initially dismissed the special affirmative defenses of respondents, stating they failed to prove tenancy. Despite an ocular inspection, the RTC referred the case to the Department of Agrarian Reform Adjudication Board (DARAB) based on allegations of an agrarian dispute. Buncio sought reconsideration but was denied. The Court of Appeals (CA) dismissed her certiorari petition against the RTC's resolution, deeming the recourse premature and ruling that her cause could be addressed through the DAR. Buncio then appealed to the Supreme Court.

 

Whether or not Buncio is entitled for Certiorari.

 

NO. The instant petition lacks merit as the Court of Appeals (CA) rightly dismissed Buncio's Petition for Certiorari due to its incorrect remedy. The CA emphasized that Buncio had alternative remedies available before the Department of Agrarian Reform Adjudication Board (DARAB). The CA's decision cited Section 50-A of RA 6657, amended by RA 9700, which mandates the automatic referral of cases with allegations of agrarian nature and involving parties like farmers, farmworkers, or tenants to the DAR. The CA also clarified that Buncio did not acquire a vested right from a previous RTC order, as jurisdiction over the subject matter is granted by law, not by previous court rulings. It highlighted the factual nature of the core issue – the existence of a tenancy relationship – and the role of the DARAB and the DAR in agrarian disputes. The CA concluded that Buncio's immediate resort to the CA through a Petition for Certiorari was improper and correctly rejected by the appellate court.

 

 

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