**Facts:** This case originates from an agricultural tenancy dispute over a parcel of land in Sta. Rosa, Laguna, designated as Lot No. 2175, registered under the name of respondent Leon Carpo and his brother. The land, devoted to rice and corn production and consisting of 3.5 hectares, was tenanted by Domingo Pastolero, whose rights were later assumed by his widow Adoracion Pastolero and son Elpidio Pastolero upon his death. Adoracion transferred her tenancy rights to petitioner Otilia Sta. Ana for P72,500.00, a transaction recognized by Leon Carpo. Despite initial harmony, disputes arose over lease rental payments and the agricultural nature of the land, prompting an ejectment complaint by the Carpos against the petitioners for non-payment of increased lease rentals, a claim contested by the petitioners.
The complaint led to a legal battle traversing various forums: from the Provincial Agrarian Reform Adjudicator (PARAD), which ordered the petitioners’ ejectment and declared the land not covered by agrarian reform laws, to the Department of Agrarian Reform Adjudication Board (DARAB), which reversed the PARAD’s decision, upholding the petitioners’ rights to the land. The Court of Appeals (CA), however, reverted to the PARAD’s position, emphasizing the petitioners’ failure to pay the lease and the land’s reclassification to non-agricultural use, a finding contested by the petitioners before the Supreme Court (SC) on grounds including the CA’s alleged overreach on matters pertinent to the DAR’s jurisdiction.
**Issues:**
1. Whether the CA erred in ruling that the subject land had been properly reclassified as non-agricultural.
2. Whether the petitioners’ failure to pay lease rentals was sufficient ground for their ejectment.
**Court’s Decision:**
The Supreme Court granted the petition, reversing the CA’s decision and reinstating the DARAB’s ruling, which favored the petitioners. The SC found the CA and PARAD had acted beyond their jurisdiction in adjudicating matters squarely within the competence of the DAR, particularly regarding the land’s agrarian status and the right of retention. On the payment of lease rentals, the Court found that the petitioners did not willfully or deliberately fail to pay, as evidenced by their attempts to settle the dues, which were rebuffed by the respondents.
**Doctrine:**
1. The doctrine of primary jurisdiction dictates that courts should refrain from settling a dispute when its resolution is initially vested in an administrative body of special competence.
2. Security of tenure for agricultural lessees under Republic Act No. 3844, indicating that failure to pay lease rentals warrants ejectment only if the non-payment is willful and deliberate.
**Class Notes:**
– **Doctrine of Primary Jurisdiction:** Courts should defer to the appropriate administrative body (the DAR, in agrarian cases) the resolution of a controversy falling under the agency’s special competence.
– **Security of Tenure for Agricultural Lessees (Republic Act No. 3844, Section 36):** Tenants can only be dispossessed for lawful causes and failure to pay lease rentals, if the non-payment is proven to be willful and deliberate.
– **Procedural Due Process:** The need to provide all parties the opportunity to be heard and to submit evidence in support of their position, especially in cases involving the administrative implementation of laws by specialized bodies.
**Historical Background:**
This case emphasizes the evolving jurisprudence on agricultural tenancy relations in the Philippines, highlighting the tension between the rights of tenants for security of tenure and the rights of landlords seeking to reclassify their land for more profitable uses. Additionally, it spotlights the critical role of administrative agencies like the DAR in determining questions pivotal to the implementation of agrarian reform policies, underscoring the doctrine of primary jurisdiction and the procedural requirements for ejectment of agricultural lessees under Philippine law.
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