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Jurisdiction (Section 50) and rules of procedure adopt a leasehold system pursuant to RA 3844. E.O. No.

adopt a leasehold system pursuant to RA 3844. E.O. No. 229 vests quasi-judicial
powers on the DAR to determine and adjudicate "agrarian reform matters" subject
of Proclamation No. 229.8 We hold that the right of private respondents to adopt a
Quismundo v. CA, 201 SCRA 609 (1991) leasehold system under RA 3844 is distinct and separate and not affected by the
enactment of E.O. No. 229 and, hence, may be enforced pursuant to the judicial
This petition for review on certiorari seeks the reversal of the decision and resolution of mechanism provided for by RA 3844.9
respondent Court of Appeals in C.A.-G.R. SP No. 16418,1 dated November 29, 1989 and
October 9, 1990, respectively, which upheld the jurisdiction of the Regional Trial Court of Petitioner's motion for reconsideration was denied by respondent Court of Appeals in its
Angeles City, Branch 58, in AGRA. Case No. 5174.2 resolution dated October 9, 1990.10 Not satisfied therewith, petitioner is now before us
raising the sole issue of jurisdiction.
It appears that on February 19, 1988, private respondents, as tenants of petitioner, filed a
complaint with the trial court praying that their relationship with petitioner be changed from It is the contention of petitioner that the Regional Trial Court of Angeles City has no
share tenancy to a leasehold system, pursuant to Section 4 of Republic Act No. 3844, as jurisdiction to try the case at bar considering that the exclusive original jurisdiction to
amended, their request therefor having been denied by petitioner.3 adjudicate agrarian cases has already been vested in the Department of Agrarian Reform
(DAR) by Executive Order No. 229, as amended by Republic Act No. 6657.
On March 2, 1988, private respondents further filed a motion for the issuance of an order
authorizing the supervision by the deputy sheriff of the court of the harvesting and We find said contention tenable.
liquidation of the 1987-1988 sugarcane crops, which motion was granted by the trial court in
an order dated March 3, 1988.4
Executive Order No. 229, which provides for the mechanism for the implementation of the
Comprehensive Agrarian Reform Program instituted by Proclamation No. 131, dated July 22,
On March 16, 1988, petitioner filed a motion to dismiss on the ground of lack of cause of 1987, vests in the Department of Agrarian Reform quasi-judicial powers to determine and
action since the law that should allegedly govern the relationship of the parties is Act No. adjudicate agrarian reform matters. The pertinent provision of said executive order reads as
4115, as amended by Commonwealth Act No. 271, and not Republic Act No. 3844, as follows:
amended. The trial court denied the motion for lack of merit in an order dated June 2, 1988.5
SECTION 17. Quasi-Judicial Powers of the DAR. — The DAR is hereby vested with
On June 18, 1988, petitioner filed a motion for reconsideration of the denial order, invoking quasi-judicial powers to determine and adjudicate agrarian reform matters, and
as an additional ground the lack of jurisdiction of the court over the case under the authority shall have exclusive original jurisdiction over all matters involving implementation
and by reason of the Comprehensive Agrarian Reform Program, specifically Executive Order of agrarian reform, except those falling under the exclusive original jurisdiction of
No. 229 and Republic Act No. 6657.6 the DENR and the Department of Agriculture (DA).

Pending the resolution of said motion for reconsideration, private respondents filed another The DAR shall have powers to punish for contempt and to issue subpoena,
motion dated November 9, 1988, for the supervision of harvesting. On December 6, 1988, subpoena duces tecum and writs to enforce its order or decisions.
the trial court granted the motion of private respondents and denied petitioner's motion for
reconsideration.7
The decisions of the DAR may, in proper cases, be appealed to the Regional Trial
Courts but shall be immediately executory notwithstanding such appeal.
Petitioner then elevated the controversy to respondent court on a petition for certiorari but,
as stated at the outset, said court upheld the jurisdiction of the court below, ruling that:
The above quoted provision should be deemed to have repealed 11 Section 12 (a) and (b) of
Presidential Decree No. 946 which invested the then courts of agrarian relations with original
Second. The right of the private respondents to choose leasehold tenancy is exclusive jurisdiction over cases and questions involving rights granted and obligations
governed by RA 3844. We find nothing in Proclamation No. 131, E.O. No. 229 and imposed by presidential issuances promulgated in relation to the agrarian reform program.
RA 6657 divesting the trial court of jurisdiction over the case. To be sure, RA 6657
was enacted on June 10, 1988 or later than the filing of the Complaint in AGRA
Formerly, under Presidential Decree No. 946, amending Chapter IX of Republic Act No. 3844,
Case No. 5174 on February 13, 1988. On the other hand, sec. 27 of E.O. 229
the courts of agrarian relations had original and exclusive jurisdiction over "cases involving
approved on July 22, 1987 provides that "... the provisions of RA 3844 and other
the rights and obligations of persons in the cultivation and use of agricultural land except
agrarian laws not inconsistent with this order shall have suppletory effect." We see
those cognizable by the National Labor Relations Commission" and "questions involving
no inconsistency between RA 3844 and E.O. No. 229 with respect to the jurisdiction
rights granted and obligations imposed by laws, Presidential Decrees, Orders, Instructions,
of the trial court over the cause of action of the private respondent who desires to
Rules and Regulations issued and promulgated in relation to the agrarian reform program," It is also worth noting at this juncture that the resolution of this case by the Department of
except those matters involving the administrative implementation of the transfer of land to Agrarian Reform is to the best advantage of private respondents since it is in a better
the tenant-farmer under Presidential Decree No. 27 and amendments thereto which shall be position to resolve agrarian disputes, being the administrative agency possessing the
exclusively cognizable by the Secretary of Agrarian Reform.12 necessary expertise on the matter. Further, the proceedings therein are summary in nature
and the department is not bound by technical rules of procedure and evidence, to the end
In 1980, upon the passage of Batas Pambansa Blg. 129, otherwise known as the Judiciary that agrarian reform disputes and other issues will be adjudicated in a just, expeditious and
Reorganization Act, the courts of agrarian relations were integrated into the regional trial inexpensive action or proceeding.15
courts and the jurisdiction of the former was vested in the latter courts.13
WHEREFORE, the petition at bar is GRANTED. The decision of the Court of Appeals is
However, with the enactment of Executive Order No. 229, which took effect on August 29, REVERSED and another judgment is hereby rendered declaring NULL and VOID the orders of
1987, fifteen (15) days after its release for publication in the Official Gazette, 14 the regional the lower court dated March 3, 1988, June 2, 1988 and December 6, 1988. The respondent
trial courts were divested of their general jurisdiction to try agrarian reform matters. The said judge, or whosoever now presides over the court a quo or to which the case is assigned, is
jurisdiction is now vested in the Department of Agrarian Reform. ordered to cease and desist from further proceeding with AGRA Case No. 5176 which is
hereby dismissed for lack of jurisdiction, without prejudice, however, to the refiling of the
same with the Department of Agrarian Reform
Thus, in the case at bar, the Regional Trial Court of Angeles City, at the time private
respondents filed their complaint, was already bereft of authority to act on the same. The
allegation of private respondents that their complaint was filed on November 3, 1987, and
not on February 13, 1988 as found by the Court of Appeals, is immaterial since as of either
date Executive Order No. 229 was already in effect. Merits, not technicalities

The foregoing holding is further sustained by the passage of Republic Act No. 6657, the
Diaz, et al. v. Mesias, Jr., G.R. No. 156345, March 4, 2004
Comprehensive Agrarian Reform Law, which took effect on June 15, 1988. The said law
contains provisions which evince and support the intention of the legislature to vest in the
Department of Agrarian Reform exclusive jurisdiction over all agrarian reform matters. This is a petition for review on certiorari under Rule 45 of the Rules of Court assailing the
June 29, 2002 Resolution1of the Court of Appeals in CA-G.R. SP No. 70596, which dismissed
the petition on technical grounds, and its November 29, 2002 Resolution, which denied
Section 50 of said Act substantially reiterates Section 17 of Executive Order No. 229 vesting in
petitioners’ motion for reconsideration.
the Department of Agrarian Reform exclusive and original jurisdiction over all matters
involving the implementation of agrarian reform, to wit:
Petitioners are the owners of a 1.2 hectare riceland located at Brgy. Guintigi-an, Ormoc City,
being tilled by, among others, Carlos Mesias, Sr., father of respondent Carlos Mesias, Jr.
SECTION 50. 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 On May 16, 1991, respondent began cultivating the land. Six years later, respondent
agrarian reform, except those falling under the exclusive jurisdiction of the requested that he be granted a homelot within the riceland by petitioners and that the share
Department of Agriculture (DA) and the Department of Environment and Natural tenancy system be changed to leasehold system. Petitioners denied both requests. Hence,
Resources (DENR). respondent brought the matter to the Barangay Agrarian Reform Committee for mediation.
No settlement was reached because petitioners failed to appear.
xxx xxx xxx
Respondent elevated the case to the Municipal Agrarian Reform Office (MARO) of the
Department of Agrarian Reform. After conducting mediation proceedings between the
In addition, Sections 56 and 57 thereof provide for the designation by the Supreme Court of
parties, the MARO concluded that respondent is not a bona fide tenant of the petitioners
at least one (1) branch of the regional trial court within each province to act as a special
considering that he is a member of the immediate farm household of his father, Carlos
agrarian court. The said special court shall have original and exclusive jurisdiction only over
Mesias, Sr. Thus, respondent filed a petition with the Provincial Adjudicator of Leyte who
petitions for the determination of just compensation to landowners and the prosecution of
dismissed the petition and declared that petitioner is not a tenant de jure of the 1.2 riceland
criminal offenses under said Act. Said provisions thus delimit the jurisdiction of the regional
subject of this case, rather it is his father, Carlos Mesias, Sr. who is the tenant thereof.
trial court in agrarian cases only to these two instances.
Respondent appealed the case to the Department of Agrarian Reform Adjudication Board The petition is meritorious.
(DARAB), which reversed the decision of the Provincial Adjudicator. The dispositive portion of
the decision of the DARAB reads: We agree with petitioners’ contention that the dismissal of the petition on purely technical
grounds was unwarranted. In denying due course to the petition, the appellate court gave
WHEREFORE, by reason of all the foregoing, the decision of the Honorable Prospero I. premium to form and failed to consider the substantial rights of the parties.
Rapada, dated October 27, 1997, is hereby SET ASIDE and new decision is hereby issued:
Rule 43, Section 6 of the Rules of Court provides:
1. Declaring petitioner Carlos Mesias, Jr. as the tenant de jure of the named
respondents in the subject farmlot; The petition for review shall (a) state the full names of the parties to the case, without
2. Ordering the respondents and/or the administrator of said land to maintain impleading the court or agencies either as petitioners or respondents; (b) contain a concise
petitioner in the peaceful possession and cultivation of subject farmlot; statement of the facts and issues involved and the grounds relied upon for the review; (c) be
3. Ordering the petitioner to withdraw the money deposited with the Land Bank of accompanied by a clearly legible duplicate original or a certified true copy of the award,
the Philippines, Ormoc City representing the lease rentals payable to the judgment, final order or resolution appealed from, together with certified true copies of such
respondents for the crop years 1996 and 1997 and update payment of other material portions of the record referred to therein and other supporting papers; and (d)
rentals due and demandable; contain a sworn certification against forum shopping as provided in the last paragraph of
4. Ordering the respondents to grant petitioner a homelot with an area of not more section 2, Rule 42. The petition shall state the specific material dates showing that it was filed
than 3% of the total area of the tenanted ricefarm but not more than 1,000 square within the period fixed herein. (2a)
meters during the existence of the tenancy relations between the parties;
5. Enjoining the parties to execute a written leasehold contract agreement
In Kalayaan Arts and Crafts, Inc. v. Anglo,5 it was held that Section 6 of Rule 43 of the Rules of
pursuant to law;
Court does not require that all of the supporting papers or annexes accompanying the
6. Ordering the Municipal Agrarian Reform Officer of Ormoc City to assist the
petition should be certified true copies or duplicate originals. What is mandatory is that
parties in the proper determination of the terms and conditions of the contract
clearly legible duplicate originals or certified true copies of the judgment or final orders of
pursuant to law and the customs and practices of the locality;
the lower courts be attached to the petition.
7. Ordering the same MARO to render a report within 15 days upon receipt of this
order as to its implementation to DARAB Appellate Board copy furnished DARAB
Secretariat. A careful perusal of the records of the case shows that the petitioners substantially complied
with the procedural requirements of Rule 43, Section 6 of the Rules of Court. Attached to the
petition for review as annexes are legible certified true copies of the decision of the
SO ORDERED.2
DARAB,6 the Resolution of the Motion for Reconsideration by the DARAB, 7 and the decision
of the Provincial Adjudicator.8 The attachment of the final decisions of these quasi-
Petitioners’ motion for reconsideration3 was denied; hence a petition for review was filed judicial agencies are sufficient in order for the Court of Appeals to give due course to the
with the Court of Appeals under Rule 43 of the Rules of Court. petition, instead of dismissing the same on the ground of petitioners’ failure to attach copies
of the pleadings and other supporting documents. Nevertheless, even if the pleadings and
The Court of Appeals dismissed the petition due to defective certification against forum other supporting documents were not attached to the petition, the dismissal was
shopping and failure to attach clearly legible copies of pertinent portions of the records and unwarranted because the entire records of the case will eventually be elevated to the
other supporting documents pursuant to Rule 43, Section 6 of the Rules of Court. appellate court, pursuant to Rule 43, Section 11 of the Rules of Court.

Petitioners filed a motion for reconsideration, attaching thereto legible copies of the records Cases should be determined on the merits after all parties have been given full opportunity
and other supporting documents. The July 29, 2002 Resolution was partly reconsidered by to ventilate their causes and defenses, rather than on technicalities or procedural
the Court of Appeals, insofar as the defective certification of forum shopping is concerned, imperfections. Rules of procedure are mere tools designed to expedite the decision or
but held that petitioners failed to comply with the procedural requirements of Rule 43, resolution of cases and other matters pending in court. A strict and rigid application of rules,
Section 6 of the Rules of Court. resulting in technicalities that tend to frustrate rather than promote substantial justice, must
be avoided. In fact, Rule 1, Section 6 of the Rules of Court states that the Rules shall be
Hence, the instant petition for review4 on the issue: whether or not the petition for review liberally construed in order to promote their objective of ensuring the just, speedy and
filed by the petitioners before the Court of Appeals complies with the requirements set in inexpensive disposition of every action and proceeding.9
Rule 43, Section 6 of the Rules of Court.
WHEREFORE, in view of the foregoing, the instant petition is GRANTED. The Resolutions of
July 29 2002 and November 29, 2002 of the Court of Appeals are SET ASIDE. The instant case
is REMANDED to the Court of Appeals for further proceedings.