Almuete vs Andres, 369 SCRA 619 (2001) Ronald

Facts : Petitioner Almuerte is the owner of ari!ultural land awarded to him "#
$ational Resettlement and Reha"ilitation Administration% &or 22 #ears, Almuete and
his famil# farmed the su"'e!t land% (owever, res)ondent, thru the assistan!e of
Ararian Reform *e!hnoloist, was a"le to !ause the land awarded to him%
Res)ondent !laimed that )etitioner waived all his rihts as $ARA settler due to )oor
health, that Almuete sold the su"'e!t )ro)ert# to one +asilat who in turn
transferred the said )ro)ert# to res)ondent Andes% ,hen -AR transferred the
ownershi) of )ro)ert# to Andes, the latter, a!!om)anied "# 10 )ersons armed with
"olos and "laded im)lements, entered the )ro)ert#, !laimin e.!lusive riht of
ownershi) and )ossession% Petitioner /led a !om)laint with the -AR onl# to /nd out
that the land was alread# transferred to Andes% Conse0uentl#, Almuete /led an
a!tion for !onve#an!e and re!over# of )ossession with the R*C, 1sa"ela% R*C ruled in
favor of )etitioner% *he de!ision "e!ame /nal%
+ar!elo Andres /led a )etition for !ertiorari with the CA !ontendin that the su"'e!t
)ro)ert# is ari!ultural and thus R*C had no 'urisdi!tion over the !ase% 2i3ewise,
"e!ause the oriinal a!tion is one for e'e!tment, the +*C and not the R*C should "e
the 'urisdi!tion of the !ase% 1n e4e!t, res)ondent !laims that the de!ision of R*C is
void% CA ranted the )etition of Andres% *hus, the a))eal%
Issue: ,hether or not R*C has 'urisdi!tion over the !ase% ,hether or not the !ause
of a!tion is e'e!tment%
Held: Petition is ranted%
Ratio5
*he a!tion /led "# )etitioners "efore the R*C was for re!over# of )ossession and
re!onve#an!e% 1t was a !ontrovers# relatin to ownershi) of the farmland, whi!h is
"e#ond the am"it of the )hrase 6ararian dis)ute%7 $o 'uridi!al tie of landowner and
tenant was alleed "etween )etitioners and res)ondents, let alone that whi!h would
so !hara!teri8ed the relationshi) as an ararian dis)ute%
Ararian dis)ute refers to an# !ontrovers# relatin to tenurial arranements,
whether leasehold, stewardshi) or otherwise, over lands devoted to ari!ulture,
in!ludin dis)utes !on!ernin farmwor3ers asso!iations or re)resentation of
)ersons in neotiatin, /.in, maintainin, !hanin or see3in to arrane terms or
!onditions of su!h tenural arranement%
&rom the foreoin, it is !lear that the 'urisdi!tion of the -ARA9 is limited to !ases
involvin a tenan!# relationshi) "etween the )arties% CA therefore ravel# erred
when it ranted the )etition for !ertiorari and held that the trial !ourt had no
'urisdi!tion over the !ase%
2i3ewise, the !ase is not for e'e!tment, "ut rather one of )ossession% 1t is not the
!a)tion of the )leadin "ut the alleations therein that determine the nature of the
a!tion% A !lose )erusal of the amended !om)laint shows that )etitioners )ra#ed for
the !an!ellation of the !erti/!ate of title in the name of +ar!elo Andres, and that
the# "e de!lared the a"solute owners of the land in dis)ute%