Case Digest: Isidro vs Court of Appeals, G.R. No. 105586, December 15, 1993, 228 SCRA 503

Isidro vs Court of Appeals
G.R. No. 105586
December 15, 1993
228 SCRA 503

Facts:
Respondent, Natividad Gutierrez is the owner of a parcel of land with an area of 4.5 hectares located in Barrio Sta. Cruz, Gapan, Nueva Ecija. In 1985, Aniceta Garcia, sister of private respondent and also the overseer of the latter, allowed petitioner Remigio Isidro to occupy the swampy portion of the abovementioned land, consisting of one (1) hectare, in order to augment his (petitioner’s) income to meet his family’s needs. The occupancy of a portion of said land was subject to the condition that petitioner would vacate the land upon demand. Petitioner occupied the land without paying any rental and converted the same into a fishpond.

In 1990, private respondent through her overseer demanded from petitioner the return of the land, but the latter refused.

A complaint for unlawful detainer was filed by private respondent against petitioner before the Municipal Trial Court (MTC) of Gapan, Nueva Ecija. Petitioner set up the following defenses: (a) that the complaint was triggered by his refusal to increase his lease rental; (b) the subject land is a fishpond and therefore is agricultural land; and (c) that lack of formal demand to vacate exposes the complaint to dismissal for insufficiency of cause of action.
MTC on  30 May 1991, dismissed the complaint, ruling that the land is agricultural and therefore the dispute over it is agrarian which is under the original and exclusive jurisdiction of the courts of agrarian relations as provided in Sec. 12(a) of Republic Act No. 946 (now embodied in the Revised Rules of Procedure of the Department of Agrarian Reform Adjudication Board).
Private respondent filed an appeal before the RTC of Gapan, Nueva Ecija, whichaffirmed MTC’s decision in toto. Private respondent appealed to CA.

On 27 February 1992, CA reversed and set aside the decision of the RTC, ordering petitioner to vacate the parcel of land in question and surrender possession thereof to private respondent, and to pay private respondent the sum of P5,000.00 as and for attorney’s fees and expenses of litigation. Petitioner moved for reconsideration but was denied.

Issue:
Whether or not the Municipal Trial Court has the jurisdiction in this case.

Held:
Yes. An agrarian dispute refers to any controversy relating to tenurial arrangements, whether leasehold, tenancy, stewardship or otherwise, over lands devoted to agriculture, including disputes concerning farm workers 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 Republic Act No. 6657 and other terms and conditions of transfer of ownership from landowners to farm workers, 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.It is irrefutable in the case at bar that the subject land which used to be an idle, swampy land was converted by the petitioner into a fishpond. And it is settled that a fishpond is an agricultural land.

But a case involving an agricultural land does not automatically make such case an agrarian dispute upon which the DARAB has jurisdiction.
(Reiterates essential requisites of tenancy relationship)
The fact remains that the existence of all the requisites of a tenancy relationship was not proven by the petitioner. In the absence of a tenancy relationship, the complaint for unlawful detainer is properly within the jurisdiction of the Municipal Trial Court.