Lawyerly

GR No. 165676

2010-11-22

BRION, J.

Under Batas Pambansa Blg. 129,[24] as amended by R.A. No. 7691,[25] the MTC shall have exclusive original jurisdiction over cases of forcible entry and unlawful detainer. The RRSP[26] governs the remedial aspects of these suits.[27]

GR No. 165676

2010-11-22

JOSE MENDOZA v. NARCISO GERMINO

BRION, J.

Under the RRSP, the MTC is duty-bound to conduct a preliminary conference[36] and, if necessary, to receive evidence to determine if such tenancy relationship had, in fact, been shown to be the real issue.[37] The MTC may even opt to conduct a hearing on the special and affirmative defense of the defendant, although under the RRSP, such a hearing is not a matter of right.[38] If it is shown during the hearing or conference that, indeed, tenancy is the issue, the MTC should dismiss the case for lack of jurisdiction.[39]

GR No. 172400

2009-06-23

ZOSIMO OCTAVIO v. ENRICO R. PEROVANO

QUISUMBING, J.

Under Batas Pambansa Blg. 129,[25] as amended by Rep. Act No. 7691,[26] the MTC shall have exclusive original jurisdiction over cases of forcible entry and unlawful detainer. The Revised Rules on Summary Procedure[27] governs the remedial aspects of such suits.[28]

GR No. 169691

2008-07-23

PEDRITO SALMORIN v. DR. PEDRO ZALDIVAR

CORONA, J.

All these elements must concur. It is not enough that they are alleged. To divest the MCTC of jurisdiction, these elements must all be shown to be present.[13]

GR No. 143111

2007-06-07

LORETO REYES v. SPS. HONORIO AND JOSEFINA B. JOSON

SANDOVAL-GUTIERREZ, J.

Petitioner insists he was hired to work on the fishpond as bantay-kasama for 14 years; that he maintained a 50-50 sharing arrangement with respondents; and that his status as such has ripened into a bona fide tenant by operation of law. Suffice it to state that the records of this case fail to show there was a sharing of harvests between petitioner and the owner of the fishpond. Besides, the fact of crop sharing by itself is not enough to establish tenancy as it is not unusual for a landowner to receive the produce of the land from a caretaker who sows thereon.[7]

GR NO. 150350

2006-08-22

KOJI YASUMA v. HEIRS OF CECILIO S. DE VILLA

CORONA, J.

The fact that the corporation admitted receiving the proceeds of the loan did not amount to ratification of the loan. It accepted the amount from de Villa, its president at that time, in good faith. Good faith is always presumed.[24] Petitioner did not show that the corporation acted in bad faith.

GR NO. 157491

2006-06-20

SPS. PROCESO AMURAO AND MINERVA AMURAO v. SPS. JACINTO VILLALOBOS AND HERMINIGILDA VILLALOBOS

CHICO-NAZARIO, J.

As defined under Section 3(d) of Republic Act No. 6657, otherwise known as the "Comprehensive Agrarian Reform Law," 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 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 landowner 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. It refers to any controversy relating to, inter alia, tenancy over lands devoted to agriculture.[22]

GR NO. 144652

2005-12-16

ARCADIO B. DANDOY v. ZACARIAS TONGSON

AUSTRIA-MARTINEZ, J.

Furthermore, the fact that Lot No. 294 is an agricultural land does not ipso facto make it an agrarian dispute within the jurisdiction of the DARAB.[16] For the present case to fall within DARAB jurisdiction, there must exist a tenancy relationship between the parties. An allegation that an agricultural tenant tilled the land in question does not make the case an agrarian dispute.[17]

GR NO. 144652

2005-12-16

ARCADIO B. DANDOY v. ZACARIAS TONGSON

AUSTRIA-MARTINEZ, J.

Thus, the Agricultural Leasehold Contracts in question (Exhs. "C" & "J") are null and void ab initio and legally inexistent; and hence, the plaintiffs' cause of action in this case has not prescribed (Articles 1409 and 1410 of the Civil Code).[22] The rule is that findings of fact of trial courts are accorded great respect by appellate courts. Unless some facts of substance that could overturn the decision had been omitted or overlooked, appellate courts will not disturb their findings.[23]

GR NO. 147081

2005-12-09

PLANTERS DEVELOPMENT BANK v. FRANCISCO GARCIA

CORONA, J.

Well-settled is the rule that persons dealing with property covered by a Torrens Certificate of Title may rely on the face of the certificate. As a rule, they are not required to go beyond what appears therein. Good faith is likewise presumed.[23] Garcia failed to show that PDB acquired the property in bad faith. We thus hold that PDB was a mortgagee in good faith and acquired the subject land validly.

GR No. 161973

2005-11-11

FRANCISCO RAMOS v. STATELAND INVESTMENT CORPORATION

CALLEJO, SR., J.

The Court has ruled that when a tenancy is merely averred as a special and affirmative defense to a complaint for unlawful detainer, the MTC does not automatically lose its jurisdiction over the said action. The MTC is duty-bound to conduct a preliminary conference and, if necessary, to receive evidence to determine if such tenancy relationship had, in fact, been shown to be the real issue. The MTC may even opt to conduct a hearing on the special and affirmative defense of the defendant, although under the Rules on Summary Procedure, such a hearing is not a matter of right.[34] If it is shown during the hearing or conference that, indeed, tenancy is the issue, the MTC should dismiss the case for lack of jurisdiction.[35]

GR No. 167748

2005-11-08

HEIRS OF RAFAEL MAGPILY v. HERMINIGILDO DE JESUS

YNARES-SANTIAGO, J.

In the same vein, the receipts presented by private respondent does not prove sharing in the agricultural production. Some receipts show that private respondent sold coconuts to several persons. The others do not reflect if the coconuts sold were that of Magpily's, or if the unlabeled computations reflected therein truly pertain to the sale of the agricultural products of the land owner. Moreover, even assuming that Magpily during his lifetime benefited from the produce of the land, this fact alone is not enough to establish tenancy. In Rivera v. Santiago,[23] we stressed that it is not unusual for a landowner to receive the produce of the land from a caretaker who sows thereon. The fact of receipt, without an agreed system of sharing, does not ipso facto create a tenancy.

	GR No. 165676 2010-11-22	JOSE MENDOZA v. NARCISO GERMINO BRION, J.
Under Batas Pambansa Blg. 129,[24] as amended by R.A. No. 7691,[25] the MTC shall have exclusive original jurisdiction over cases of forcible entry and unlawful detainer. The RRSP[26] governs the remedial aspects of these suits.[27]
	GR No. 165676 2010-11-22	JOSE MENDOZA v. NARCISO GERMINO BRION, J.
Under the RRSP, the MTC is duty-bound to conduct a preliminary conference[36] and, if necessary, to receive evidence to determine if such tenancy relationship had, in fact, been shown to be the real issue.[37] The MTC may even opt to conduct a hearing on the special and affirmative defense of the defendant, although under the RRSP, such a hearing is not a matter of right.[38] If it is shown during the hearing or conference that, indeed, tenancy is the issue, the MTC should dismiss the case for lack of jurisdiction.[39]
	GR No. 172400 2009-06-23	ZOSIMO OCTAVIO v. ENRICO R. PEROVANO QUISUMBING, J.
Under Batas Pambansa Blg. 129,[25] as amended by Rep. Act No. 7691,[26] the MTC shall have exclusive original jurisdiction over cases of forcible entry and unlawful detainer. The Revised Rules on Summary Procedure[27] governs the remedial aspects of such suits.[28]
	GR No. 169691 2008-07-23	PEDRITO SALMORIN v. DR. PEDRO ZALDIVAR CORONA, J.
All these elements must concur. It is not enough that they are alleged. To divest the MCTC of jurisdiction, these elements must all be shown to be present.[13]
	GR No. 143111 2007-06-07	LORETO REYES v. SPS. HONORIO AND JOSEFINA B. JOSON SANDOVAL-GUTIERREZ, J.
Petitioner insists he was hired to work on the fishpond as bantay-kasama for 14 years; that he maintained a 50-50 sharing arrangement with respondents; and that his status as such has ripened into a bona fide tenant by operation of law. Suffice it to state that the records of this case fail to show there was a sharing of harvests between petitioner and the owner of the fishpond. Besides, the fact of crop sharing by itself is not enough to establish tenancy as it is not unusual for a landowner to receive the produce of the land from a caretaker who sows thereon.[7]
	GR NO. 150350 2006-08-22	KOJI YASUMA v. HEIRS OF CECILIO S. DE VILLA CORONA, J.
The fact that the corporation admitted receiving the proceeds of the loan did not amount to ratification of the loan. It accepted the amount from de Villa, its president at that time, in good faith. Good faith is always presumed.[24] Petitioner did not show that the corporation acted in bad faith.
	GR NO. 157491 2006-06-20	SPS. PROCESO AMURAO AND MINERVA AMURAO v. SPS. JACINTO VILLALOBOS AND HERMINIGILDA VILLALOBOS CHICO-NAZARIO, J.
As defined under Section 3(d) of Republic Act No. 6657, otherwise known as the "Comprehensive Agrarian Reform Law," 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 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 landowner 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. It refers to any controversy relating to, inter alia, tenancy over lands devoted to agriculture.[22]
	GR NO. 144652 2005-12-16	ARCADIO B. DANDOY v. ZACARIAS TONGSON AUSTRIA-MARTINEZ, J.
Furthermore, the fact that Lot No. 294 is an agricultural land does not ipso facto make it an agrarian dispute within the jurisdiction of the DARAB.[16] For the present case to fall within DARAB jurisdiction, there must exist a tenancy relationship between the parties. An allegation that an agricultural tenant tilled the land in question does not make the case an agrarian dispute.[17]
	GR NO. 144652 2005-12-16	ARCADIO B. DANDOY v. ZACARIAS TONGSON AUSTRIA-MARTINEZ, J.
Thus, the Agricultural Leasehold Contracts in question (Exhs. "C" & "J") are null and void ab initio and legally inexistent; and hence, the plaintiffs' cause of action in this case has not prescribed (Articles 1409 and 1410 of the Civil Code).[22] The rule is that findings of fact of trial courts are accorded great respect by appellate courts. Unless some facts of substance that could overturn the decision had been omitted or overlooked, appellate courts will not disturb their findings.[23]
	GR NO. 147081 2005-12-09	PLANTERS DEVELOPMENT BANK v. FRANCISCO GARCIA CORONA, J.
Well-settled is the rule that persons dealing with property covered by a Torrens Certificate of Title may rely on the face of the certificate. As a rule, they are not required to go beyond what appears therein. Good faith is likewise presumed.[23] Garcia failed to show that PDB acquired the property in bad faith. We thus hold that PDB was a mortgagee in good faith and acquired the subject land validly.
	GR No. 161973 2005-11-11	FRANCISCO RAMOS v. STATELAND INVESTMENT CORPORATION CALLEJO, SR., J.
The Court has ruled that when a tenancy is merely averred as a special and affirmative defense to a complaint for unlawful detainer, the MTC does not automatically lose its jurisdiction over the said action. The MTC is duty-bound to conduct a preliminary conference and, if necessary, to receive evidence to determine if such tenancy relationship had, in fact, been shown to be the real issue. The MTC may even opt to conduct a hearing on the special and affirmative defense of the defendant, although under the Rules on Summary Procedure, such a hearing is not a matter of right.[34] If it is shown during the hearing or conference that, indeed, tenancy is the issue, the MTC should dismiss the case for lack of jurisdiction.[35]
	GR No. 167748 2005-11-08	HEIRS OF RAFAEL MAGPILY v. HERMINIGILDO DE JESUS YNARES-SANTIAGO, J.
In the same vein, the receipts presented by private respondent does not prove sharing in the agricultural production. Some receipts show that private respondent sold coconuts to several persons. The others do not reflect if the coconuts sold were that of Magpily's, or if the unlabeled computations reflected therein truly pertain to the sale of the agricultural products of the land owner. Moreover, even assuming that Magpily during his lifetime benefited from the produce of the land, this fact alone is not enough to establish tenancy. In Rivera v. Santiago,[23] we stressed that it is not unusual for a landowner to receive the produce of the land from a caretaker who sows thereon. The fact of receipt, without an agreed system of sharing, does not ipso facto create a tenancy.

FLORDELIZA RIVERA v. GREGORIA SANTIAGO