JURISDICTION/AGRARIAN DISPUTE/TENANCY RELATIONSHIP, FOR PURPOSES OF

DETERMININGWHETHER OR NOT THE MUNICIPAL TRIAL COURT HAS JURISDICTION OVER THE
CASE AND IN ORDER TODETERMINE THE EXISTENCE OF AN AGRARIAN DISPUTE, THE TRIAL COURT
SHOULD NOT HAVEDISREGARDED THE DEFENDANT'S ANSWER FOR HAVING BEEN FILED OUT
OF TIME

Jaime P. Corpin vs. Amor S. Vivar and the Honorable Court of Appeals
G.R. No. 137350 (June 19, 2000)
Facts:
Petitioner filed a complaint for ejectment against the private respondent with the
Municipal Trial Court of Guiguinto, Bulacan. For failure to timely file his Answer with Motion
to Dismiss the court deemed the case submitted for judgment and rendered a decision ordering
private respondent to vacate the land in dispute. Private respondent appealed the case to
the Regional Trial Court and submitted documents to support his claim that he is a tenant of the
petitioner's lot. The Regional Trial Court in turn, dismissed the case for lack of jurisdiction.
Subsequently, petitioner filed a Petition for Review of the said Decision with the Court of
Appeals. The latter upheld the Regional Trial Court's finding and dismissed the petition for lack
of merit. Hence, this Petition.
Issues:
Whether or not the Court of Appeals erred in the interpretation of Section 7, Rule 40 of
the Revised Rules of Court as it considered all the documents submitted by the Private
Respondent for the first time together with the memorandum Whether or not the Honorable
Court of Appeals erred in ruling that there was a landlord-tenant relationship between the parties
Held:
In the case of Bayog vs. Natino which the appellate court cited, we held that the
metropolitan circuit trial court, which dismissed defendant's Answer for having been filed out of
time and decided the case based on the allegations in the complaint, should not have disregarded
defendant's Answer and should have heard and received the evidence for the purpose of
determining whether or not it had jurisdiction over the case. What were presented to the
municipal trial court were limited to the following:
(1) Pagtitibay dated February 21, 1996 signed by Angel Torres, Chairman of the
BARC of Tabang;
(2) Affidavit of Dr. Teodoro Placido dated April 22, 1996;
(3) Sinumpaang Salaysay of Ambrosio T. Mendoza dated April 22, 1996;and
(4) Sinumpaang Salaysay of private respondent dated April 22, 1996.
Considering the foregoing, it is clear that there is a need to conduct a hearing whereby both
parties may present evidence which may shed light on the issue of the municipal trial court's
jurisdiction over the case. Consequently, the Regional Trial Court's finding that there exists
a landlord-tenant relationship between petitioner and respondent, which was based on
the documents attached by private respondent to his memoranda in the Regional Trial Court only
on appeal and were not previously presented to the municipal trial court in the original case,
must be set aside. The records of the case must be remanded to the Municipal Trial Court
and hear the issue of jurisdiction.

INTERVENTION/PARTIES-IN-INTEREST, ASSUMING THAT THE LANDS ARE "CARPABLE", IT IS NOT

THEPETITIONER BUT THE MEMBERS THEREOF WHO ARE THE PROPER PARTIES-IN-INTEREST IN THE
SUBJECTCONTROVERSY

Kooperatiba ng Sandigan ng Magsasakang Pilipino, Inc. (KSMP) vs. Department of

Agrarian Reform Adjudication Board, et al.
G.R. No. 139051 (June 26, 2000)
Facts:
The case stemmed from the Order dated May 27, 1975 by then DAR Secretary Conrado
Estrella granting the request for conversion of 1,837.30 hectares of agricultural land situated in
Nasugbu, Batangas into residential, commercial, industrial and other urban purposes. In essence,
the Order stated that the subject land is not economically suited for agricultural cultivation and
that if there are any tenant-tillers, disturbance compensation should be paid to them in
accordance with law. Fifteen (15) occupants assisted by the Federation of Free Farmers (FFF)
claiming to be tenants of a forty-four (44) hectare portion filed a motion for reconsideration of
the said Order. But prior to such, former President Ferdinand B. Marcos issued Proclamation No.
1520 on November 27, 1975 declaring the Municipalities of Maragond on and Ternate, Cavite
and Nasugbu, Batangas as tourist zones more suitable for residential, commercial, industrial and
urban uses. In December 1989, apparently unaware of the conversion orders and presidential
proclamation, then DAR Secretary Miriam Defensor-Santiago issued Notices of Acquisition
dated December 14-27, 1989.Private respondents, Gonzalo Puyat and Sons, filed their objections
to these Santiago notices. Thereafter, on January 22, 1991, Secretary Benjamin T. Leong who
succeeded Secretary Santiago rule don the validity of the questioned Order issued on May 27,
1975 and denied the Motion for Reconsideration holding that pursuant to Proclamation No.
1520, Maragondon, Ternate and Nasugbu are declared as tourist zones. Meanwhile, on May 14,
1991, the private respondents filed a Petition with the DARAB docketed as DARAB Case No.
0335 for the purpose of implementing the Conversion Orders which in effect suggested the
manner of invalidating the Santiago Notices as it was contrary to the Leong Order of January
22,1991. Petitioner KSMP (Kooperatiba ng Sandigan ng Magsasakang Pilipino, Inc.) filed a
complaint-in-intervention on the aforementioned case. This was dismissed by the
DAR. Subsequently, KSMP filed a Petition for Certiorari with the Court of Appeals docketed as
G.R. No. 47813 imputing grave abuse of discretion on the DARAB. The CA dismissed the same.
Hence, this Petition.
Held:
We find no error with the ruling of the CA that petitioner's cause is lost considering that
the Conversion Orders have long become final and executory. There was, therefore, no more case
to which it could intervene. The complaint-in-intervention was, therefore, correctly dismissed
pursuant to the 1997 Rules of Civil Procedure.
Petitioner's insistence that there was no final disposition yet of the conversion case, as in fact,
DARAB Case No. 0335 was initiated by the private respondents is untenable. A perusal of the
records reveal that DARAB Case No. 0335 was filed by the private respondents for the purpose
of implementing the Conversion Orders particularly the fixing of the final disturbance
compensation to the legitimate farmer-occupants. The complaint-in-intervention, however, puts
in issue petitioner's alleged tenancy relationship and security of tenure which the DARAB does

not have any jurisdiction. Furthermore, petitioner, a juridical entity, has no personality to file the
instant petition to intervene in the case as the real parties-in-interest are the members thereof who
were not even recognized as the rightful tenants occupying the subject land. As observed by the
DAR, "members of petitioner are merely holding on to an expectancy that they will become the
beneficiaries assuming that the land is still CARPable." The fact, however, remains that the land
in question has already been excluded from the purview of the Comprehensive Agrarian Reform
Law (CARL) by the Estrella and Leong Orders which had long become final and executory.