Documente Academic
Documente Profesional
Documente Cultură
FELICIANO, J.:
There are before us for review the following: (1) the decision of the Court
of First Instance of Negros Occidental, Branch 3, in Civil Case No. 13823;
and (2) the decision of the Court of Agrarian Relations, 11th Judicial
District, in CAR Case No. 76. Both of these decisions dismissed the
petitioners' complaints for lack of jurisdiction.
Petitioners Ramona R. Locsin, Teresita R. Guanzon, Celina R. Sibug, Ma.
Lusia R. Perez, Editha R. Ylanan and Ana Marie R. Benedicto were coowners of a large tract of agricultural land known as "Hacienda Villa
Regalado" located in Barrio Panubigan, Canlaon City, Negros Occidental.
The tract of land was covered by Transfer Certificate of Title No. T-494 and
there more particularly described in the following terms:
TRANSFER CERTIFICATE OF TITLE
NO. T-494
A parcel of land (Lot 2-G) of the subdivision plan Psd28446, Sheet 2, being a portion of Lot 2 (remaining
portion) described in plan II-6992, G.L.R.O. Record No.
133), situated in the Barrio of Panubigan, Municipality of
Canlaon Province of Negros Occidental, Bounded on the
N., by Lot 2-A of the subdivision plan; on the E., and S.,
by Binalbagan River; on the W., by Lot 2-E of the
subdivision plan; on the NW., by Lots 2-F and 2-A of the
subdivision plan. ...containing an area of THREE
MILLION THIRTY-THREE THOUSAND AND FORTY
EIGHT (3,033,048) square meters, more or less. 1
A portion of this land, known as Lot No. 2-C-A-3 and consisting of an area
of 60.07464 hectares, was subject to the lifetime usufructuary rights of
respondent Helen Schon:. The bulk of this lot was cultivated by the
following lessees-tenants who customarily delivered the rental to Helen
Schon:
TENANTS
1. Carlos Panaligan
2.00 Ha.
2. Amado Marquez
1.50 Ha.
3. Herbert Pedros
1.50 Ha.
2.00 Ha.
5. Hugo Aguilos
3.50 Ha.
6. Alberto Gubaton
8.90 Ha.
7. Hulo Aguilos
1.32 Ha.
2.25 Ha.
9. Carlos Panaligan
1.25 Ha.
5.35 Ha.
2.00 Ha.
4.70 Ha.
13 Eliseo Gelongos
3.00 Ha.
5.55 Ha.
1.5884 Ha.
1.85 Ha.
8.30 Ha.
TOTAL
56.555 Ha. 2
On 22 May 1978, petitioners filed against the spouses Joseph and Helen
Schon Civil Case No. 13828 in the then Court of First Instance of Negros
Occidental, for collection of rentals plus damages with prayer for
preliminary injunction. There petitioners claimed that since the land subject
to Helen Schon's usufructuary rights was among the parcels of land which
colectively had been declared by the DAR as a land reform area pursuant to
Presidential Decree No. 27, the rental payments which the respondent
spouses had been colecting from the tenants really pertained and should be
delivered to petitioners, beginning from 21 October 1972, as constituting or
forming part of the amortization payments for the land to be made by the
tenants. Petitioners sought in that case to recover from the Schons all such
previous rentals or the money value thereof, and prayed for injunction to
prevent the respondents from collecting any further rental payments from
the tenants of the land involved.
Upon the other hand, in their Answer filed on 12 July 1978, the respondents
Schon contended that under the provisions of Section 12 of Presidential
Decree No. 946 dated 17 June 1976, and given the facts involved in Civil
Case No. 13823, the Court of First Instance was bereft of jurisdiction over
the subject matter of the case. That jurisdiction, the Schon spouses urged,
was vested in the CAR instead. Respondents further argued that, upon the
assumption arguendo that the Court of First Instance did have jurisdiction,
Article 609 of the Civil Code must in any case be applied by that court in
resolving the case . 5
The respondent tenants, for their part, agreed with the Schons that there was
no tenancy relationship existing in respect of the land cultivated by them,
since such land had already been brought within the ambit of "Operation
Land Transfer", and prayed that the petitioners and the usufructuary be
required to litigate among themselves their respective rights before the
proper court.
3. Dismissal of Civil Case No. 13823 and CAR Case No.
76
(Emphasis supplied)
The Regional Trial Courts have full authority and jurisdiction to interpret
and apply both the mass of statutes and rules and regulations relating to land
reform and the general civil law, including the law on usufruct. Unlike a
regional trial court sitting as a probate court, a region al trial court seized of
an agrarian dispute and interpreting and applying statutes and administrative
rules and regulations concerning land reform and the sliminations of
agricultural tenancy relationships, continues to act as a court of general and
plenary jurisdiction. Section 44 of b.P. Blg. 129 abolished the Courts of
Agrarian Relations and did not re-create them.
We note that resolution of the underlying substantive issues here raised
requires examination of both land reform statutes and related rules and
regulations (and as well the practice of the relevant administrative agency or
executive department) and the Civil Code provisions on usufruct.
Mindful of the length of timewhich has gone by since the first of the
consolidated cases reched this Court, and in the effort to render expeditious
justice, we have considered whether we should now confront and resolve
the issue relating to the legal character of the payments made by the
respondents tenants-lessees since 21 October 1972 to respondent Helen
Schon, as well as the issue relating to the possible application of Article 609
of the Civil Code. Because, however, of the nature and importance of the
first issue, and considering that the pleadings and the records of theses two
(2) cases are bare of any substantial discussion by the parties on both issues,
the Court feels it would not be prudent to resolve those issues without
further proceedings. We are convinced, however, that those issues are
primarily, if not wholly, issues of law rather than of fact and that hence there
appears no need to remand these cases to the Regional Trial Court for
further proceedings there. Instead, we shall require the parties to file
memoranda on the issues above indicated, and the direct the Solicitor
General to intervene in these cases and to file a memorandum addressing
the same issues.
ACCORDINGLY, the Court Resolved to: (1) REQUIRE the petition and
private respondents in G.R. Nos. 51333 and 52289 to file simultaneous
memoranda addressing the substantive issues identified above, within thirty
(30) days from notice hereof, and to FURNISH the Solicitor General a copy