Rodrigo Almuete and Ana Almuete vs. Marcelo Andres and The Court of Appeals G.R. No.

122276 (November 20, 2001) Facts: Petitioner Rodrigo Almuete was awarded a 72,587 square meter parcel of land located at San Vicente, Angadanan, Isabela by the then National Resettlement and Rehabilitation Administration (NARRA) on March 25, 1957. Since then, Almuete and his family farmed the subject property peacefully and exclusively. However, unknown to petitioner, an Agrarian Reform Technologist by the name of Leticia Gragasin on August 17, 1979 filed false reports making it appear that Almuete has waived his right as awardee and made it appear that one Marcelo Andres was the actual occupant of the land from 1967 to date. Consequently, DAR issued OCT No. P-52521 in the name of respondent who, in turn, accompanied by ten persons armed with bolos, immediately entered the subject property claiming exclusive right of ownership and possession. Almuete complained to the DAR and wasted no time in filing an action for reconveyance and recovery of possession against Marcelo Andres with the RTC of Cauayan, Isabela. The Trial Court rendered a Decision in favor of Almuete which became final and executory upon Marcelo Andres's failure to appeal. The latter filed a petition for certiorari to prevent the implementation of the writ of execution which was entertained by the Court of Appeals. Hence, this Petition. Issue: Whether or not this case is considered an agrarian dispute. Whether or not regular courts have jurisdiction. Held: The Supreme Court reversed the decision of the Court of Appeals and said thatit gravely erred when it granted the petition for certiorari and held that the trial court had no jurisdiction over the subject matter of the action between petitioners and respondent. The action filed by petitioners was cognizable by the regular courts. The Supreme Court held that this case is not of an agrarian dispute. An agrarian dispute is refers to any controversy relating to tenurial 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 arrangements. It includes any controversy relating to compensation of lands acquired under this Act and other terms and conditions of transfer of ownership from landowners to farmworkers, tenants and other agrarian reform beneficiaries, whether the disputants stand in the proximate relation of farm operator and beneficiary, landowner and tenant, or lessor and lessee. In this case no juridical tie of landowner and tenant was alleged between petitioners and respondent, let alone that which would so characterize the relationship as an agrarian dispute. In fact, petitioner and respondent were contending parties for the ownership of the same parcel of

land. The action filed by petitioners before the trial court was for recovery of possession and reconveyance of title: there is no "agrarian dispute" involving tenancy relationship between the parties that the issue should fall within the jurisdiction of the DARAB.