Where a question of jurisdiction between the Department of Agrarian Reform Adjudication Board (DARAB) and the Regional Trial Court (RTC) is at the core of a dispute, basic jurisprudential tenets come into play. It is the rule that jurisdiction of a tribunal, including a quasi-judicial body or government agency, over the nature and subject matter of a petition or complaint is determined by the material allegations therein and the character of the relief prayed irrespective of whether the petitioner or complainant is entitled to any or all such reliefs. In the same vein, jurisdiction of the court over the subject matter of the action is not affected by the pleas or theories set up by the defendant in the an answer or a motion to dismiss. Otherwise, jurisdiction will become dependent almost entirely upon the whims of the defendant. Only the DARAB, as the DAR's quasi-judicial body, can determine and adjudicate all agrarian disputes, cases, controversies, and matters or incidents involving the implementation of the CARP.
The absence of tenurial arrangement, whether leasehold, tenancy, stewardship or otherwise, cannot be overlooked. When no juridical tie of landownership and tenancy is allege, a controversy cannot be categorized as an agrarian dispute. Hence, jurisdiction is with the regular courts.
(DEARBC v. Jesus Sangumay & Sonny Labunos, G.R. No. 180013. January 31, 2011)
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