SANCHEZ V MARIN

(Doctrine of Adherence of Jurisdiction)

FACTS:
David Felix owned a fishpond. Jaime Sanchez was instituted as a tenant on the said fishpond, with a 50/50 sharing
agreement. After a few years, Felix sold and transferred ownership of the subject fishpond to the Marins. As new owners
of the fishpond, they entered into a civil law agreement with their mother, Zemaida, which was renewable yearly.
Zenaida then made an arrangement with Sanchez wherein Sanchez would receive a regular salary and a 20%
share in the net profit of the fishpond. When her lease agreement with her children expired, Zenaida ordered Sanchez to
vacate the premises. Sanchez refused, asserting that he was a tenant of the fishpond and not a mere contractual worker;
hence, he had the right to its peaceful possession and security of tenure.
On 21 July 1986, the petitioner filed a Complaint before the Regional Trial Court (RTC) of Lucena City, in
which he asked the court to declare him as a tenant of the subject fishpond. On 20 July 1987, the RTC of Lucena City
rendered a Decision in favor of the petitioner,
As Sanchez was already declared as an agricultural tenant of the fishpond, he filed a petition to the Provincial
Agrarian Reform Adjudicator (PARAD) for the fixing of leasehold rentals for his use of the fishpond. However, Zenaida
countered this application by filing a case with the PARAD to eject Sanchez for failure to pay the rent and for failure to
render an accounting. The PARAD consolidated the 2 cases and ruled in favor of Sanchez.
Zenaida appealed to the DARAB, which affirmed the PARAD decision. The CA reversed the ruling, stating that
the DARAB lacked jurisdiction over the case. It stated that Sec. 2 of RA 7881, which amended Sec. 10 of RA 6657,
excluded private lands actually, directly, and exclusively used for prawn farms and fishponds from the coverage of the
CARL, so that the operation of a fishpond is no longer considered an agricultural activity. Since the cases are not agrarian
disputes, then the DARAB could not have validly acquired jurisdiction over the case.
ISSUE:
W/N the DARAB has jurisdiction over the case.
HELD:

YES. The present case was instituted as early as 1991 when the law applicable was still RA 6657, and fishponds
and prawn farms were not yet exempted/excluded from the CARL coverage. At that time, there was an agrarian dispute
between the parties. Prior to the enactment of RA 7881 in 1995, the case was already pending appeal before the DARAB.
And being in the nature of a substantive law, the amendments introduced by Republic Act No. 7881 to Republic Act No.
6657 in the year 1995 cannot be given a retroactive application as to deprive the petitioner of his rights under the previous
agrarian legislation. Hence, the aforesaid amendments cannot be made to apply to divest the DARAB of its jurisdiction of
the case. Once jurisdiction is acquired by the court, it remains with it until the full termination of the case.