Machete et, al., vs CA Case Digest GR No. 109093 November 20, 1995

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

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Facts:

            Private respondent filed 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 respondent’s 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:

1   Whether or not RTC has jurisdiction over cases for collection of back rentals from leasehold tenants.

Ruling:

1   The court held that collection of back rentals from leasehold tenants is within the jurisdiction of DARAB and the SC defined “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, fixing, 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 offense 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.