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GR No. 200751

2015-08-17

LEONEN, J.

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.[89]

GR No. 174908

2013-06-17

DARMA MASLAG v. & ELIZABETH MONZON

DEL CASTILLO, J.

As discussed above, the MTC has original and exclusive jurisdiction over the subject matter of the case; hence, there is no other way the RTC could have taken cognizance of the case and review the court a quo's Judgment except in the exercise of its appellate jurisdiction. Besides, the new RTC Judge who penned the May 4, 2004 Resolution, Judge Diaz de Rivera, actually treated the case as an appeal despite the October 22, 2003 Order. He started his Resolution by stating, "This is an appeal from the Judgment rendered by the Municipal Trial Court (MTC) of La Trinidad Benguet"[35] and then proceeded to discuss the merits of the "appeal." In the dispositive portion of said Resolution, he reversed the MTC's findings and conclusions and remanded residual issues for trial with the MTC.[36] Thus, in fact and in law, the RTC Resolution was a continuation of the proceedings that originated from the MTC. It was a judgment issued by the RTC in the exercise of its appellate jurisdiction. With regard to the RTC's earlier October 22, 2003 Order, the same should be disregarded for it produces no effect (other than to confuse the parties whether the RTC was invested with original or appellate jurisdiction). It cannot be overemphasized that jurisdiction over the subject matter is conferred only by law and it is "not within the courts, let alone the parties, to themselves determine or coveniently set aside."[37] Neither would the active participation of the parties nor estoppel operate to confer original and exclusive jurisdiction where the court or tribunal only wields appellate jurisdiction over the case.[38] Thus, the CA is correct in holding that the proper mode of appeal should have been a Petition for Review under Rule 42 of the Rules of Court, and not an ordinary appeal under Rule 41.

GR No. 171624

2010-12-06

BF HOMES v. MANILA ELECTRIC COMPANY

LEONARDO-DE CASTRO, J.

Lastly, the Court herein already declared that the RTC not only lacked the jurisdiction to issue the writ of preliminary injunction against MERALCO, but that the RTC actually had no jurisdiction at all over the subject matter of the Petition of BF Homes and PWCC in Civil Case No. 03-0151. Therefore, in addition to the dissolution of the writ of preliminary injunction issued by the RTC, the Court also deems it appropriate to already order the dismissal of the Petition of BF Homes and PWCC in Civil Case No. 03-0151 for lack of jurisdiction of the RTC over the subject matter of the same. Although only the matter of the writ of preliminary injunction was brought before this Court in the instant Petition, the Court is already taking cognizance of the issue on the jurisdiction of the RTC over the subject matter of the Petition. The Court may motu proprio consider the issue of jurisdiction. The Court has discretion to determine whether the RTC validly acquired jurisdiction over Civil Case No. 03-0151 since, to reiterate, jurisdiction over the subject matter is conferred only by law. Jurisdiction over the subject matter cannot be acquired through, or waived by, any act or omission of the parties. Neither would the active participation of the parties nor estoppel operate to confer jurisdiction on the RTC where the latter has none over a cause of action.[29] Indeed, when a court has no jurisdiction over the subject matter, the only power it has is to dismiss the action.[30]

GR No. 172217

2009-09-18

SPS. LYDIA FLORES-CRUZ AND REYNALDO I. CRUZ v. SPS. LEONARDO AND ILUMINADA GOLI-CRUZ

CORONA, J.

This issue of assessed value as a jurisdictional element in accion publiciana was not raised by the parties nor threshed out in their pleadings.[27] Be that as it may, the Court can motu proprio consider and resolve this question because jurisdiction is conferred only by law.[28] It cannot be acquired through, or waived by, any act or omission of the parties.[29]

GR No. 170182

2009-06-18

LEONARDO TARONA v. CA

LEONARDO-DE CASTRO, J.

In order to establish a tenancy relationship, the following essential requisites must concur: (1) the parties are the landowner and the tenant or agricultural lessee; (2) the subject matter of the relationship is an agricultural land; (3) there is consent between the parties to the relationship; (4) the purpose of the relationship is to bring about agricultural production; (5) there is personal cultivation on the part of the tenant or agricultural lessee; and (6) the harvest is shared between the landowner and the tenant or agricultural lessee.[17] All these requisites are necessary to create a tenancy relationship and the absence of one or more will not make the alleged tenant a de facto tenant.[18]

GR No. 176942

2008-08-28

NICORP MANAGEMENT v. LEONIDA DE LEON

YNARES-SATIAGO, J.

There is a tenancy relationship if the following essential elements concur: 1) the parties are the landowner and the tenant or agricultural lessee; 2) the subject matter of the relationship is an agricultural land; 3) there is consent between the parties to the relationship; 4) the purpose of the relationship is to bring about agricultural production; 5) there is personal cultivation on the part of the tenant or agricultural lessee; and 6) the harvest is shared between landowner and tenant or agricultural lessee.[23] All the foregoing requisites must be proved by substantial evidence and the absence of one will not make an alleged tenant a de jure tenant.[24] Unless a person has established his status as a de jure tenant, he is not entitled to security of tenure or covered by the Land Reform Program of the Government under existing tenancy laws.[25]

GR No. 172146

2008-07-30

CORNES v. LEAL REALTY CENTRUM CO.

CHICO-NAZARIO, J.

Tenants are defined as persons who - in themselves and with the aid available from within their immediate farm households - cultivate the land belonging to or possessed by another, with the latter's consent, for purposes of production, sharing the produce with the landholder under the share tenancy system, or paying to the landholder a price certain or ascertainable in produce or money or both under the leasehold tenancy system.[28]

GR No. 169691

2008-07-23

PEDRITO SALMORIN v. DR. PEDRO ZALDIVAR

CORONA, J.

Contrary to the findings of the MCTC, both the RTC and the CA found that there was no tenancy relationship between Salmorin and Zaldivar. A tenancy relationship cannot be presumed.[11] In Saul v. Suarez, [12] we held:There must be evidence to prove the tenancy relations such that all its indispensable elements must be established, to wit: (1) the parties are the landowner and the tenant; (2) the subject is agricultural land; (3) there is consent by the landowner; (4) the purpose is agricultural production; (5) there is personal cultivation; and (6) there is sharing of the harvests. All these requisites are necessary to create tenancy relationship, and the absence of one or more requisites will not make the alleged tenant a de facto tenant.

GR No. 173415

2008-03-28

Mariano Tanenglian Petitioner v. Silvestre Lorenzo

CHICO-NAZARIO, J.

For DARAB to have jurisdiction over a case, there must exist a tenancy relationship between the parties. A tenancy relationship cannot be presumed. There must be evidence to prove the tenancy relations such that all its indispensable elements must be established, to wit: (1) the parties are the landowner and the tenant; (2) the subject is agricultural land; (3) there is consent by the landowner; (4) the purpose is agricultural production; (5) there is personal cultivation; and (6) there is sharing of the harvests. All these requisites are necessary to create tenancy relationship, and the absence of one or more requisites will not make the alleged tenant a de facto tenant.[27]

GR NO. 148044

2007-10-19

ANTONIO MASAQUEL v. JAIME ORIAL

TINGA, J.

In order for a tenancy agreement to arise, it is essential to establish all its indispensable elements, viz: (1) the parties are the landowner and the tenant or agricultural lessee; (2) the subject matter of the relationship is an agricultural land; (3) there is consent between the parties to the relationship; (4) the purpose of the relationship is to bring about agricultural production; (5) there is personal cultivation on the part of the tenant or agricultural lessee; and (6) the harvest is shared between the landowner and the tenant or agricultural lessee.[18] All these requisites are necessary to create a tenancy relationship, and the absence of one or more requisites will not make the alleged tenant a de facto tenant.[19]

GR NO. 148044

2007-10-19

ANTONIO MASAQUEL v. JAIME ORIAL

TINGA, J.

In view of the absence of a tenancy relationship, the case falls outside the jurisdiction of the DARAB. Thus, it is cognizable by the regular courts.[34] Consequently, the complaint filed by respondent was rightfully dismissed by the provincial adjudicator.

GR No. 167748

2005-11-08

HEIRS OF RAFAEL MAGPILY v. HERMINIGILDO DE JESUS

YNARES-SANTIAGO, J.

For DARAB to have jurisdiction over a case, there must exist a tenancy relationship between the parties. A tenancy relationship cannot be presumed. There must be evidence to prove the tenancy relations such that all its indispensable elements must be established, to wit: (1) the parties are the landowner and the tenant; (2) the subject is agricultural land; (3) there is consent by the landowner; (4) the purpose is agricultural production; (5) there is personal cultivation; and (6) there is sharing of the harvests. All these requisites are necessary to create tenancy relationship, and the absence of one or more requisites will not make the alleged tenant a de facto tenant.[14]

	GR No. 200751 2015-08-17	MONICO LIGTAS v. PEOPLE LEONEN, J.
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.[89]
	GR No. 174908 2013-06-17	DARMA MASLAG v. & ELIZABETH MONZON DEL CASTILLO, J.
As discussed above, the MTC has original and exclusive jurisdiction over the subject matter of the case; hence, there is no other way the RTC could have taken cognizance of the case and review the court a quo's Judgment except in the exercise of its appellate jurisdiction. Besides, the new RTC Judge who penned the May 4, 2004 Resolution, Judge Diaz de Rivera, actually treated the case as an appeal despite the October 22, 2003 Order. He started his Resolution by stating, "This is an appeal from the Judgment rendered by the Municipal Trial Court (MTC) of La Trinidad Benguet"[35] and then proceeded to discuss the merits of the "appeal." In the dispositive portion of said Resolution, he reversed the MTC's findings and conclusions and remanded residual issues for trial with the MTC.[36] Thus, in fact and in law, the RTC Resolution was a continuation of the proceedings that originated from the MTC. It was a judgment issued by the RTC in the exercise of its appellate jurisdiction. With regard to the RTC's earlier October 22, 2003 Order, the same should be disregarded for it produces no effect (other than to confuse the parties whether the RTC was invested with original or appellate jurisdiction). It cannot be overemphasized that jurisdiction over the subject matter is conferred only by law and it is "not within the courts, let alone the parties, to themselves determine or coveniently set aside."[37] Neither would the active participation of the parties nor estoppel operate to confer original and exclusive jurisdiction where the court or tribunal only wields appellate jurisdiction over the case.[38] Thus, the CA is correct in holding that the proper mode of appeal should have been a Petition for Review under Rule 42 of the Rules of Court, and not an ordinary appeal under Rule 41.
	GR No. 171624 2010-12-06	BF HOMES v. MANILA ELECTRIC COMPANY LEONARDO-DE CASTRO, J.
Lastly, the Court herein already declared that the RTC not only lacked the jurisdiction to issue the writ of preliminary injunction against MERALCO, but that the RTC actually had no jurisdiction at all over the subject matter of the Petition of BF Homes and PWCC in Civil Case No. 03-0151. Therefore, in addition to the dissolution of the writ of preliminary injunction issued by the RTC, the Court also deems it appropriate to already order the dismissal of the Petition of BF Homes and PWCC in Civil Case No. 03-0151 for lack of jurisdiction of the RTC over the subject matter of the same. Although only the matter of the writ of preliminary injunction was brought before this Court in the instant Petition, the Court is already taking cognizance of the issue on the jurisdiction of the RTC over the subject matter of the Petition. The Court may motu proprio consider the issue of jurisdiction. The Court has discretion to determine whether the RTC validly acquired jurisdiction over Civil Case No. 03-0151 since, to reiterate, jurisdiction over the subject matter is conferred only by law. Jurisdiction over the subject matter cannot be acquired through, or waived by, any act or omission of the parties. Neither would the active participation of the parties nor estoppel operate to confer jurisdiction on the RTC where the latter has none over a cause of action.[29] Indeed, when a court has no jurisdiction over the subject matter, the only power it has is to dismiss the action.[30]
	GR No. 172217 2009-09-18	SPS. LYDIA FLORES-CRUZ AND REYNALDO I. CRUZ v. SPS. LEONARDO AND ILUMINADA GOLI-CRUZ CORONA, J.
This issue of assessed value as a jurisdictional element in accion publiciana was not raised by the parties nor threshed out in their pleadings.[27] Be that as it may, the Court can motu proprio consider and resolve this question because jurisdiction is conferred only by law.[28] It cannot be acquired through, or waived by, any act or omission of the parties.[29]
	GR No. 170182 2009-06-18	LEONARDO TARONA v. CA LEONARDO-DE CASTRO, J.
In order to establish a tenancy relationship, the following essential requisites must concur: (1) the parties are the landowner and the tenant or agricultural lessee; (2) the subject matter of the relationship is an agricultural land; (3) there is consent between the parties to the relationship; (4) the purpose of the relationship is to bring about agricultural production; (5) there is personal cultivation on the part of the tenant or agricultural lessee; and (6) the harvest is shared between the landowner and the tenant or agricultural lessee.[17] All these requisites are necessary to create a tenancy relationship and the absence of one or more will not make the alleged tenant a de facto tenant.[18]
	GR No. 176942 2008-08-28	NICORP MANAGEMENT v. LEONIDA DE LEON YNARES-SATIAGO, J.
There is a tenancy relationship if the following essential elements concur: 1) the parties are the landowner and the tenant or agricultural lessee; 2) the subject matter of the relationship is an agricultural land; 3) there is consent between the parties to the relationship; 4) the purpose of the relationship is to bring about agricultural production; 5) there is personal cultivation on the part of the tenant or agricultural lessee; and 6) the harvest is shared between landowner and tenant or agricultural lessee.[23] All the foregoing requisites must be proved by substantial evidence and the absence of one will not make an alleged tenant a de jure tenant.[24] Unless a person has established his status as a de jure tenant, he is not entitled to security of tenure or covered by the Land Reform Program of the Government under existing tenancy laws.[25]
	GR No. 172146 2008-07-30	CORNES v. LEAL REALTY CENTRUM CO. CHICO-NAZARIO, J.
Tenants are defined as persons who - in themselves and with the aid available from within their immediate farm households - cultivate the land belonging to or possessed by another, with the latter's consent, for purposes of production, sharing the produce with the landholder under the share tenancy system, or paying to the landholder a price certain or ascertainable in produce or money or both under the leasehold tenancy system.[28]
	GR No. 169691 2008-07-23	PEDRITO SALMORIN v. DR. PEDRO ZALDIVAR CORONA, J.
Contrary to the findings of the MCTC, both the RTC and the CA found that there was no tenancy relationship between Salmorin and Zaldivar. A tenancy relationship cannot be presumed.[11] In Saul v. Suarez, [12] we held:There must be evidence to prove the tenancy relations such that all its indispensable elements must be established, to wit: (1) the parties are the landowner and the tenant; (2) the subject is agricultural land; (3) there is consent by the landowner; (4) the purpose is agricultural production; (5) there is personal cultivation; and (6) there is sharing of the harvests. All these requisites are necessary to create tenancy relationship, and the absence of one or more requisites will not make the alleged tenant a de facto tenant.
	GR No. 173415 2008-03-28	Mariano Tanenglian Petitioner v. Silvestre Lorenzo CHICO-NAZARIO, J.
For DARAB to have jurisdiction over a case, there must exist a tenancy relationship between the parties. A tenancy relationship cannot be presumed. There must be evidence to prove the tenancy relations such that all its indispensable elements must be established, to wit: (1) the parties are the landowner and the tenant; (2) the subject is agricultural land; (3) there is consent by the landowner; (4) the purpose is agricultural production; (5) there is personal cultivation; and (6) there is sharing of the harvests. All these requisites are necessary to create tenancy relationship, and the absence of one or more requisites will not make the alleged tenant a de facto tenant.[27]
	GR NO. 148044 2007-10-19	ANTONIO MASAQUEL v. JAIME ORIAL TINGA, J.
In order for a tenancy agreement to arise, it is essential to establish all its indispensable elements, viz: (1) the parties are the landowner and the tenant or agricultural lessee; (2) the subject matter of the relationship is an agricultural land; (3) there is consent between the parties to the relationship; (4) the purpose of the relationship is to bring about agricultural production; (5) there is personal cultivation on the part of the tenant or agricultural lessee; and (6) the harvest is shared between the landowner and the tenant or agricultural lessee.[18] All these requisites are necessary to create a tenancy relationship, and the absence of one or more requisites will not make the alleged tenant a de facto tenant.[19]
	GR NO. 148044 2007-10-19	ANTONIO MASAQUEL v. JAIME ORIAL TINGA, J.
In view of the absence of a tenancy relationship, the case falls outside the jurisdiction of the DARAB. Thus, it is cognizable by the regular courts.[34] Consequently, the complaint filed by respondent was rightfully dismissed by the provincial adjudicator.
	GR No. 167748 2005-11-08	HEIRS OF RAFAEL MAGPILY v. HERMINIGILDO DE JESUS YNARES-SANTIAGO, J.
For DARAB to have jurisdiction over a case, there must exist a tenancy relationship between the parties. A tenancy relationship cannot be presumed. There must be evidence to prove the tenancy relations such that all its indispensable elements must be established, to wit: (1) the parties are the landowner and the tenant; (2) the subject is agricultural land; (3) there is consent by the landowner; (4) the purpose is agricultural production; (5) there is personal cultivation; and (6) there is sharing of the harvests. All these requisites are necessary to create tenancy relationship, and the absence of one or more requisites will not make the alleged tenant a de facto tenant.[14]

DOMINGO C. SUAREZ v. LEO B. SAUL