Agrarian Law Case Digest
Agrarian Law Case Digest
Agrarian Law Case Digest
Leonarda L. Monsanto, petitioner vs. Jesus and Teresita Zerna and Court of Appeals, respondents
The counsel of the accused opposed the decision of the RTC. He averred
that the PHP1,000.00 was due to the accused as compensation for their labor, and
equity demands that they be entitled to it, as the Court has dismissed the criminal
case against them.
The motion raised another issue whether or not the accused are entitled to
the PHP1,000.00 as compensation for their labor in harvesting and processing the
coconut into copra?
The Court found that equity was wanting in the case: 1) absence of consent
by the complainant in the harvesting and processing of coconuts into copra, and 2)
devoid of good faith because the accused did the act in an attempt to confirm their
tenancy claim.
On review, the Court of Appeals (CA) ruled that the RTC had no jurisdiction
to order private respondents to pay the petitioner the amount of PHP1, 000.00. The
dispute fell within the primary and exclusive original jurisdiction of the
Department of Agrarian Reform Adjudication Board (DARAB), as the case
involved an agricultural tenancy relationship. Given that RTC had no jurisdiction
to rule on the civil aspect of the case, ergo, it had no appellate authority over the
matter under a writ of error.
Hence, this Petition.
Leonarda L. Monsanto, petitioner vs. Jesus and Teresita Zerna and Court of Appeals, respondents
ISSUES
RULING
can arise from the action as a consequence thereof. The liability of the
defendant to return the amount received by him is not enforceable in the
criminal case but in a civil action. On the set of facts presented, the RTC did
not acquire jurisdiction to impose a civil liability to the accused, who were
acquitted.
SC upheld the CA ruling that the resolution of the issue as to who is
entitled to the PHP1, 000.00 is within the jurisdiction of the DARAB. EO
229 vested the Department of Agrarian Reform (DAR) with quasi-judicial
powers to determine and adjudicate agrarian reform matters, as well as to
exercise exclusive original jurisdiction over all matters involving the
implementation of agrarian reform.
Section 13 of EO 129-A, created the Department of Agrarian Reform
Adjudication Board (DARAB), tasked with the power and the function to
decide agrarian reform cases. The DARAB, under Section 1, paragraph (a),
Rule II of the Revised Rules of Procedure, exercises primary jurisdiction -both original and appellate -- to determine and adjudicate all agrarian
disputes, cases, controversies, and matters or incidents involving the
implementation of agrarian laws and their implementing rules and
regulations.
2) Tenancy relationship
For DARAB to have jurisdiction of the case, the tenancy relationship
between the parties must first, be established. The essential elements of
tenancy relationship are: 1) the parties are the landowner and the tenant or
Leonarda L. Monsanto, petitioner vs. Jesus and Teresita Zerna and Court of Appeals, respondents
Leonarda L. Monsanto, petitioner vs. Jesus and Teresita Zerna and Court of Appeals, respondents
The determination of who is the rightful owner of the PHP1, 000.00, balance
of the proceeds from the copra sale, is inextricably intertwined with the
resolution of the agrarian dispute between them.
SC ruled that the CA did not commit error in holding that the DARAB had
the jurisdiction upon the civil matter.
WHEREFORE, the Petition is DENIED and the assailed Decision and
Resolution are AFFIRMED.
Leonarda L. Monsanto, petitioner vs. Jesus and Teresita Zerna and Court of Appeals, respondents