Topic: Defnition of Agrarian Dispute

Lope Machete, et al., vs. CA and Celestino Villalon

Facts: Private respondent fled a complaint for collection of back rentals and damages
before the RTC of Tagbilaran City against herein petitioners. The alleged facts are:
1) That parties entered into a leasehold agreement regarding private respondents landholdings
and herein petitioners shall pay a certain amount or percentage of their harvest.
2) That herein petitioners failed to pay their respective rental despite repeated demands of
private respondent.
3) That petitioner moved to the dismissal of the case on the ground, of lack of jurisdiction over
the subject matter, arguing that the instance case is an agrarian dispute and therefore within the
jurisdiction of Department of Agrarian and Reform Adjudication Board.
Issue: Whether or not RTC has jurisdiction over cases for collection of back rentals from
leasehold tenants.
Ruling: The court held that collection of back rentals from leasehold tenants is within the
jurisdiction of DARAB and the SC defned agrarian dispute as any controversy relating to
tenural arrangements, whether leasehold, tenancy, stewardship, or otherwise, over lands
devoted to agriculture, including disputes concerning farm workers associations or
representation of persons in negotiating, fxing, maintaining, changing or seeking to arrange
terms or conditions of such tenurial agreements. However, Sec. 56 of RA 6657 confers special
jurisdiction on Special Agrarian Courts which are RTC designated by the SC, regarding
petitions for the determination of just compensation and prosecution of criminal ofense under
Act. 16.
The SC furthered averred that failure to pay back rentals pursuant to leasehold contract is an
issue which is clearly beyond the legal competence of the trial court to resolve. The doctrine of
primary jurisdiction does not warrant a court to arrogate unto itself the authority to resolve
controversy the jurisdiction over which is initially lodged with an administrative body of special
competence.
CHAMBER OF REAL ESTATE AND BUILDERS ASSOCIATIONS, INC. (CREBA), petitioner,
vs.
THE SECRETARY OF AGRARIAN REFORM, Respondent.
G.R. No. 183409 June 18, 2010
Topic:Diference between exemption, conversion & reclassifcation
Facts:
1.The Sec of Agrarian issue several DAR administrative orders (AO) 07-97 and 01-99 regarding the
conversion of agricultural lands to non-agricultural lands which includes among other things (1)
those to be converted to residential, commercial, industrial, institutional and other non-
agricultural purposes. After the issuance of these orders, several orders where again issued
amending some provisions of the earlier issued orders.
2.To address the unabated conversion of prime agricultural lands for real estate development, the
Secretary of Agrarian Reform further issued Memorandum No. 88 (along with AO No. 05-07
amending AO 01-02)on 15 April 2008, which temporarily suspended the processing and approval
of all land use conversion applications.
3.The petitioner fled a petition for Certiorari and Prohibition (with application for temporary
restraining order and/or writ of preliminary injunction) due to their claim of actual slow down of
housing projects, which, in turn, aggravated the housing shortage, unemployment and illegal
squatting problems to the substantial prejudice not only of the petitioner and its members but
more so of the whole nation. The petitioners contention:
a.When the DAR Sec issued the said order, in efect it included lands reclassifed under RA
6657 from agricultural to residential, commercial, industrial, or other non-agricultural
uses after 15 June 1988 TO BE agricultural lands for purposes of conversion,
redistribution, or otherwise. The Secretary of Agrarian Reform acted without jurisdiction
as he has no authority to expand or enlarge the legal signifcation of the term agricultural
lands through DAR AO No. 01-02. Being a mere administrative issuance, it must conform
with the statute.
Issue: In relation to reclassifcation of lands : WHETHER THE DAR SECRETARY HAS JURISDICTION
OVER LANDS THAT HAVE BEEN RECLASSIFIED AS RESIDENTIAL, COMMERCIAL, INDUSTRIAL,
OR FOR OTHER NON-AGRICULTURAL USES
Decision:
The petition was dismissed. SC ruled in favor of the DAR Sec:
o The petitioner failed to observe the doctrine of hierarchy of courts
o The instant petition is styled as a Petition for Certiorari, in essence, it seeks the
declaration by this Court of the unconstitutionality or illegality of the questioned DAR
AO. It, thus, partakes of the nature of a Petition for Declaratory Relief over which this
Court has only appellate, not original, jurisdiction.
o The DAR Sec did not act any judicial or quasi-judicial capacity nor assumed unto himself
any performance of judicial or quasi-judicial prerogative which a requisite for any action
of grave abuse of discretion amounting to lack or excess of jurisdiction. The DAR Sec
issued the orders in order to implement the land use conversion provisions of Republic
Act No. 6657. Issuance was done in the exercise of his quasi-legislative and administrative
functions.
o Executive Order No. 129-A authorized the DAR to approve or disapprove the
conversion, restructuring or readjustment of agricultural lands into non-agricultural
uses. Similarly, Section 5(l) of the same executive order has given the DAR the
exclusive authority to approve or disapprove conversion of agricultural lands for
residential, commercial, industrial, and other land uses as may be provided for by law.
The DAR Sec acted within the scope of his authority when it defned what is
agricultural land (lands not reclassifed as residential, commercial, industrial or other
non-agricultural uses before 15 June 1988" for purposes of land use conversion)
RUFINA VDA. DE TANGUB, petitioner, vs. COURT OF APPEALS, PRESIDING JUDGE of
the [CAR] RTC, Branch 4, Iligan City, and SPOUSES DOMINGO and EUGENIA MARTIL,
respondents.
Topic:Jurisdiction
Facts:
1.Petitioners (Rufna and her now deceased husband) were tenants of a land owned by the
private respondents (sps Domingo). They fled an action in the RTC of Lanao Del Norte
for damages when they claim that they were unlawfully disposed of the property.
2.The RTC dismissed the case ruling that it no longer has jurisdiction over agrarian cases
which was transferred to the DAR. The CA (after being referred by it from the SC)
afrmed the RTC decision.
Issue:Was the dismissal proper (who has jurisdiction over agrarian cases)?
Decision:
Petition is denied.
o RA 665 investing the Department of Agrarian Reform with origicnal jurisdiction,
generally, over all cases involving agrarian laws,the Department of Agrarian
Reform with original jurisdiction, generally, over all cases involving agrarian
laws. Sec 50 specifcally provides: Quasi-Judicial Powers of the DAR. The
DAR is hereby vested with primary jurisdiction to determine and adjudicate
agrarian reform matters and shall have exclusive original jurisdiction over all
matters involving the implementation of agrarian reform, except those falling
under the exclusive jurisdiction of the Department of Agriculture [DA] and the
Department of Environment and Natural Resources [DENR].
o The RTC acting as special agrarian courts are given the exclusive jurisdiction
over (1) all petitions for the determination of just compensation to land-owners
and (2) the prosecution of all criminal ofenses under