In a dispute over land rights, the Supreme Court clarified that merely claiming co-ownership does not automatically disqualify a person from also being recognized as a tenant. The court emphasized that the Department of Agrarian Reform Adjudication Board (DARAB) has the jurisdiction to determine the true nature of the relationship between landowners and tillers, especially when tenancy is alleged. This ruling protects the rights of farmers and ensures that they are not easily evicted from the land they cultivate.

When Shared Land Becomes Contested Ground: Can a Co-Owner Also Be a Tenant?

This case revolves around a parcel of land in Bulacan, originally owned by the Sarmiento family and later mortgaged to Rural Bank of Pandi, Inc. Spouses Avelina Rivera-Nolasco and Eduardo Nolasco (the petitioner spouses) claimed tenancy rights over the land, asserting that Avelina had been cultivating it since 1981. However, the bank, after foreclosing the mortgage and obtaining a writ of possession, denied their tenancy and fenced off the property, preventing the spouses from harvesting their crops. The petitioner spouses filed a complaint with the DARAB, seeking to maintain their peaceful possession and claiming damages. The bank countered that the DARAB had no jurisdiction, arguing that the land was not tenanted and that Avelina’s claim of being a co-owner contradicted any tenancy relationship.

The Court of Appeals sided with the bank, stating that co-ownership and tenancy were mutually exclusive. However, the Supreme Court disagreed. The High Court emphasized that jurisdiction is determined by the allegations in the complaint, and the petitioner spouses had sufficiently alleged a tenancy relationship. The complaint stated that Avelina had been cultivating the land as a tenant since 1981, even after it was transferred to the Rivera siblings as co-owners.

The Supreme Court underscored the significance of the allegations made by the petitioner spouses. The court reiterated that it is a basic tenet that the jurisdiction of a tribunal is determined by the nature of the complaint. In Heirs of Julian dela Cruz and Leonora Talara v. Heirs of Alberto Cruz, the Court stated:

It is axiomatic that the jurisdiction of a tribunal, including a quasi-judicial officer or government agency such as the DARAB and the PARAD, over the nature and subject matter of a petition or complaint is determined by the material allegations therein and the character of the relief prayed for, irrespective of whether the petitioner or complainant is entitled to any or all such reliefs.

Building on this principle, the Court highlighted the need for the DARAB to investigate the true nature of the relationship between the parties. Even if Avelina was indeed a co-owner, the Court questioned whether this automatically negated her claim of tenancy. The Court noted that the specifics of the co-ownership arrangement and the harvest-sharing agreement between Avelina and her siblings needed to be examined.

The Supreme Court found the CA’s ruling that “ownership is antithesis of tenancy” to be an oversimplification in the context of co-ownership. The Supreme Court further stated that, the outright dismissal of the case prevented a full presentation of the facts, potentially leading to the unjust eviction of agricultural tenants. The appellate court’s decision, according to the Supreme Court, ran the risk of granting judicial imprimatur to an extrajudicial eviction of agricultural tenants.

The Court also addressed the certifications presented by the bank, which stated that the land was not tenanted. The Court clarified that these certifications were not conclusive and did not prevent the DARAB from exercising its jurisdiction. Such certifications do not bind the courts.

The Court expressed concern that the appellate court’s decision could set a dangerous precedent, allowing unscrupulous landowners to easily evict tenants by simply offering them a share in the ownership of the land. This would undermine the State’s policy of protecting the rights of agricultural tenants and promoting social justice. After all, Section 7 of R.A. No. 3844 ordains that once the tenancy relationship is established, a tenant or agricultural lessee is entitled to security of tenure.

The Court emphasized that the law provides specific grounds for the ejectment of an agricultural tenant, as stated in Sections 8, 28, and 36 of Republic Act (R.A.) No. 3844. These include abandonment of the land, voluntary surrender, or failure to pay lease rentals. Co-ownership is not among these grounds. In Bernas v. CA and Deita, the Court had emphasized that grounds for the ejectment of an agricultural leasehold lessee are an exclusive enumeration.

In conclusion, the Supreme Court ruled that the DARAB had jurisdiction over the case and that the appellate court had erred in dismissing the complaint. The Court remanded the case to the DARAB for further proceedings, emphasizing the need to determine the true nature of the relationship between the parties and to protect the rights of agricultural tenants. The Court also echoed its ruling in Bernas v. CA and Deita:

The Court must, in our view, keep in mind the policy of the State embodied in the fundamental law and in several special statutes, of promoting economic and social stability in the countryside by vesting the actual tillers and cultivators of the soil, with rights to the continued use and enjoyment of their landholdings until they are validly dispossessed in accordance with law.

FAQs

What was the key issue in this case?	The key issue was whether the DARAB had jurisdiction over a case where the petitioner spouses claimed tenancy rights, but were also alleged to be co-owners of the land.
What did the Court rule regarding the DARAB’s jurisdiction?	The Court ruled that the DARAB did have jurisdiction, as the complaint sufficiently alleged a tenancy relationship, and the allegation of co-ownership did not automatically negate this.
Why did the Court disagree with the Court of Appeals?	The Court disagreed with the Court of Appeals’ view that co-ownership and tenancy were mutually exclusive, especially in the context of co-ownership arrangements within families.
Are certifications from MARO conclusive evidence of tenancy?	No, certifications from the Municipal Agrarian Reform Officer (MARO) are not conclusive evidence and do not prevent the DARAB from making its own determination.
What is the significance of security of tenure for tenants?	Security of tenure means that a tenant cannot be evicted from the land they cultivate except for specific causes provided by law and after due process.
What are some of the lawful causes for ejecting a tenant?	Lawful causes include abandonment of the land, voluntary surrender, failure to pay lease rentals, or conversion of the land to non-agricultural purposes.
Can a landowner evict a tenant simply by offering them co-ownership?	No, the Court expressed concern that this could be a tactic to undermine tenants’ rights and that the mere offer of co-ownership does not automatically terminate a tenancy relationship.
What is the doctrine of primary jurisdiction?	The doctrine of primary jurisdiction means that courts should defer to administrative agencies like the DARAB when the issue requires their expertise and specialized knowledge.

This case reaffirms the importance of protecting the rights of agricultural tenants and ensuring that they are not easily dispossessed of their land. The Supreme Court’s decision emphasizes the need for a thorough examination of the facts and circumstances in agrarian disputes, and for the DARAB to exercise its expertise in determining the true nature of the relationship between landowners and tillers.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.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: Spouses Avelina Rivera-Nolasco and Eduardo A. Nolasco v. Rural Bank of Pandi, Inc., G.R. No. 194455, June 27, 2018