G.R. No. 178266. July 21, 2008.
PEOPLE OF THE PHILIPPINES, petitioner, vs. SAMUEL and LORETA
VANZUELA, respondents.
Courts; Jurisdictions; It is a well-entrenched doctrine that the jurisdiction of a
tribunal over the subject matter of an action is conferred by law. It is determined by
the material allegations of the complaint or information and the law at the time the
action was commenced.—It is a well-entrenched doctrine that the jurisdiction of a
tribunal over the subject matter of an action is conferred by law. It is determined by
the material allegations of the complaint or information and the law at the time the
action was commenced. Lack of jurisdiction of the court over an action or the
subject matter of an action, cannot be cured by the silence, acquiescence, or even
by express consent of the parties. Thus, the jurisdiction of the court over the nature
of the action and the subject matter thereof cannot be made to depend upon the
defenses set up in the court or upon a motion to dismiss; otherwise, the question of
jurisdiction would depend almost entirely on the defendant. Once jurisdiction is
vested, the same is retained up to the end of the litigation.
Same; Same; The Regional Trial Court also has jurisdiction over the offense
charged since the crime was committed within its territorial jurisdiction.—The RTC
also has jurisdiction over the offense charged since the crime was committed within
its territorial jurisdiction.
Same; Same; The Regional Trial Court likewise acquired jurisdiction over the
persons of the respondents because they voluntarily submitted to the RTC’s
authority.—The RTC likewise acquired jurisdiction over the persons of the
respondents because they voluntarily submitted to the RTC’s authority. Where the
court has jurisdiction over the subject matter and over the person of the accused,
and the crime was committed within its territorial jurisdiction, the court necessarily
exercises jurisdiction over all issues that the law requires the court to resolve.
_______________
* THIRD DIVISION.
VOL. 559, JULY 21, 2008 235
People vs. Vanzuela
Same; Same; Agrarian Disputes; It is true that in Machete v. Court of Appeals
(250 SCRA 176 [1995]), this Court held that the Regional Trial Courts (RTCs) have
no jurisdiction over cases for collection of back rentals filed against agricultural
tenants by their landowners.—Based on the law and material allegations of the
information filed, the RTC erroneously concluded that it lacks jurisdiction over the
subject matter on the premise that the case before it is purely an agrarian dispute.
The cases relied upon by the RTC, namely, David v. Rivera, 420 SCRA 90 (2004)
and Philippine Veterans Bank v. Court of Appeals, 462 SCRA 336 (2005), are of
different factual settings. They hinged on the subject matter of Ejectment and
Annulment of Certificate of Land Ownership Awards (CLOAs), respectively. It is
true that in Machete v. Court of Appeals, 250 SCRA 176 (1995), this Court held that
RTCs have no jurisdiction over cases for collection of back rentals filed against
agricultural tenants by their landowners. In that case, however, what the landowner
filed before the RTC was a collection suit against his alleged tenants. These three
cases show that trial courts were declared to have no jurisdiction over civil cases
which were initially filed with them but were later on characterized as agrarian
disputes and thus, within DARAB’s jurisdiction. No such declaration has been made
by this Court with respect to criminal cases.
Same; Same; Same; It is worth stressing that even the jurisdiction over the
prosecution of criminal offenses in violation of Republic Act No. 6657 per se is
lodged with the Special Agrarian Courts (SACs) and not with the Department of
Agrarian Reform Adjudication Board (DARAB).—The law and the DARAB Rules
are deafeningly silent on the conferment of any criminal jurisdiction in favor of the
DARAB. It is worth stressing that even the jurisdiction over the prosecution of
criminal offenses in violation of RA 6657 per se is lodged with the SACs and not
with the DARAB. While indeed, the parties admit that there is an agricultural tenancy
relationship in this case, and that under the circumstances, Veneranda as landowner
could have simply filed a case before the DARAB for collection of lease rentals
and/or dispossession of respondents as tenants due to their failure to pay said lease
rentals, there is no law which prohibits landowners from instituting a criminal case
for estafa, as defined and penalized under Article 315 of the Revised Penal Code,
against their tenants. Succinctly put, though the matter before us apparently presents
an agrarian dispute, the RTC cannot shirk from its
236 SUPREME COURT REPORTS ANNOTATED
People vs. Vanzuela
duty to adjudicate on the merits a criminal case initially filed before it, based on the
law and evidence presented, in order to determine whether an accused is guilty
beyond reasonable doubt of the crime charged.
Agrarian Disputes; We now remind landowners that such prerogative of
instituting a criminal case against their tenants, on matters related to an agrarian
dispute, must be exercised with prudence, when there are clearly lawful grounds, and
only in the pursuit of truth and justice.—We must reiterate our ruling in Re:
Conviction of Judge Adoracion G. Angeles, 543 SCRA 196 (2008), that while we do
not begrudge a party’s prerogative to initiate a case against those who, in his
opinion, may have wronged him, we now remind landowners that such prerogative
of instituting a criminal case against their tenants, on matters related to an agrarian
dispute, must be exercised with prudence, when there are clearly lawful grounds,
and only in the pursuit of truth and justice.
Same; Agrarian Reform Law; What prevails today, under R.A. 6657, is
agricultural leasehold tenancy relationship, and all instances of share tenancy have
been automatically converted into leasehold tenancy.—Unfortunately for the
petitioner, these cited cases are inapplicable. People v. Carulasdulasan and Becare,
98 Phil. 8 (1954), involved a relationship of agricultural share tenancy between the
landowner and the accused. In such relationship, it was incumbent upon the tenant
to hold in trust and, eventually, account for the share in the harvest appertaining to
the landowner, failing which the tenant could be held liable for misappropriation. As
correctly pointed out by the respondents, share tenancy has been outlawed for being
contrary to public policy as early as 1963, with the passage of R.A. 3844. What
prevails today, under R.A. 6657, is agricultural leasehold tenancy relationship, and all
instances of share tenancy have been automatically converted into leasehold tenancy.
In such a relationship, the tenant’s obligation is simply to pay rentals, not to deliver
the landowner’s share. Given this dispensation, the petitioner’s allegation that the
respondents misappropriated the landowner’s share of the harvest—as contained in
the information—is untenable. Accordingly, the respondents cannot be held liable
under Article 315, paragraph 4, No. 1(b) of the Revised Penal Code.
Same; We have opted to rule on the merits of the parties’ contentions, and
hereby declare that respondents cannot be held liable for
VOL. 559, JULY 21, 2008 237
People vs. Vanzuela
estafa for their failure to pay the rental on the agricultural land subject of the
leasehold.—We hold that the trial court erred when it dismissed the criminal case for
lack of jurisdiction over the subject matter. However, we find no necessity to
remand the case to the trial court for further proceedings, as it would only further
delay the resolution of this case. We have opted to rule on the merits of the parties’
contentions, and hereby declare that respondents cannot be held liable for estafa for
their failure to pay the rental on the agricultural land subject of the leasehold.
PETITION for review on certiorari of a decision of the Regional Trial Court of
Surigao City, Br. 30.
The facts are stated in the opinion of the Court.
Jose Expeditus B. Bayana for petitioner.
Bureau of Agrarian Legal Assistance for respondents.
NACHURA, J.:
Before this Court is a Petition for Review on Certiorari1 under Rule 45 of
the Rules of Civil Procedure. The petitioner People of the Philippines
(petitioner) seeks the reversal of the Order2 dated May 18, 2007, issued by the
Regional Trial Court (RTC), Branch 30 of Surigao City, which dismissed for
lack of jurisdiction over the subject matter the criminal case for estafa filed by
private complainant Veneranda S. Paler (Veneranda) against respondents
Samuel Vanzuela (Samuel) and his wife, Loreta Vanzuela (Loreta)
(respondents). The case ostensibly involves an agrarian dispute, hence,
according to the RTC, within the exclusive original jurisdiction of the
Department of Agrarian Reform Adjudication Board (DARAB).
The antecedents are as follows:
_______________
1 Dated June 5, 2007; Rollo, pp. 3-11.
2 Particularly docketed as Criminal Case No. 6087; id., at pp. 13-16.
238 SUPREME COURT REPORTS ANNOTATED
People vs. Vanzuela
Veneranda is the wife of the late Dionisio Paler, Sr.3 who is the registered
owner of a parcel of irrigated riceland, containing an area of more than four (4)
hectares, situated in Barangay Mabini (Roxas), Mainit, Surigao del Norte, and
covered by Original Certificate of Title (OCT) No. 5747.4 One (1) hectare of
this riceland (subject property) was cultivated by the respondents as agricultural
tenants for more than ten (10) years, with an agreed lease rental of twelve and
one half (12½) cavans of palay, at 45 kilos per cavan, per harvest. The
respondents allegedly failed to pay the rentals since 1997. Initially, Veneranda
brought the matter before the Department of Agrarian Reform (DAR) Office in
Mainit, Surigao del Norte, but no amicable settlement was reached by the
parties. Thus, Veneranda filed a criminal complaint for estafa against the
respondents.
Consequently, respondents were charged in an Information5 dated February
28, 2002 which reads:
“That in about and during the period from 1997 to 2001 in Brgy. Roxas, Mainit,
Surigao del Norte, Philippines and within the jurisdiction of this Honorable Court,
said spouses Samuel and Loreta Vanzuela, conspiring, confederating and mutually
helping one another, having leased and occupied the farmland of Veneranda S. Paler
and other heirs of the late Dionesio Paler, Sr., and having harvested and accounted
for a total of 400 sacks of palay for the past 10 harvest seasons of which 25%
thereof were hold (sic) in trust by them or a total value of P80,000.00, did then and
there willfully, unlawfully and feloniously misappropriate, misapply and convert said
sum of P80,000.00 to their own use and benefit to the damage and prejudice of said
Veneranda Paler and other heirs of the late Dionesio Paler, Sr. in the aforementioned
sum of P80,000.00.
Contrary to law.”
_______________
3 Also referred to as Dionesio Paler, Sr. in other documents and pleadings.
4 Rollo, p. 37.
5 Id., at pp. 33-34.
VOL. 559, JULY 21, 2008 239
People vs. Vanzuela
Upon arraignment, respondents pleaded not guilty. During pre-trial, the
parties agreed that the respondents had been the agricultural tenants of
Veneranda for more than ten (10) years; and that the palay was harvested twice
a year on the subject property. Thereafter, trial on the merits ensued. After the
prosecution rested its case, the respondents filed a Demurrer to Evidence,6
praying that the criminal case be dismissed for failure of the petitioner to
establish the culpability of the respondents beyond reasonable doubt. Petitioner
filed a Comment/Opposition7 arguing that the respondents, as agricultural
tenants, were required by law to hold the lease rentals in trust for the landowner
and thereafter turn over the same to the latter.
In an Order8 dated May 18, 2007, the RTC dismissed the criminal case
ratiocinating, thus:
“From the averments of the information, the admissions of the parties and the
evidence adduced by the prosecution, it is easily discernable (sic) that the instant
case pertains to the non-payment of rentals by the accused to the private
complainant, involving a lease of an agricultural land by the former from the latter.
This being so, the controversy in the case at bench involves an agrarian dispute
which falls under the primary and exclusive original jurisdiction of the Department of
Agrarian Reform Adjudication Board (DARAB), pursuant to Section 1, Rule II of the
DARAB New Rules of Procedure, x x x.”
Citing our ruling in David v. Rivera9 and Philippine Veterans Bank v.
Court of Appeals,10 the RTC opined that it had no jurisdiction over the subject
matter of the case because the controversy had the character of an “agrarian
dispute.” The trial court did not find it necessary to rule on the respondents’
_______________
6 Dated December 4, 2006; id., at pp. 17-29.
7 Dated January 20, 2007; id., at pp. 30-32.
8 Supra note 2, id., at p. 14.
9 464 Phil. 1006; 420 SCRA 90 (2004).
10 G.R. No. 132561, June 30, 2005, 462 SCRA 336.
240 SUPREME COURT REPORTS ANNOTATED
People vs. Vanzuela
Demurrer to Evidence and, in fact, no mention of it was made in the assailed
Order of May 18, 2007. Hence, this petition raising the following issues:
1. WHETHER OR NOT THE HONORABLE REGIONAL TRIAL COURT
BRANCH 30, SURIGAO CITY HAS JURISDICTION OVER THE CHARGE FOR
ESTAFA EVEN IF IT INVOLVES AGRICULTURAL TENANTS OF THE
PRIVATE COMPLAINANT; [AND]
2. WHETHER OR NOT THE SEEMING “EXEMPTION” FROM CRIMINAL
PROSECUTION OF AGRICULTURAL TENANTS FOR ESTAFA WOULD
CONTRAVENE THE PROVISIONS OF SECTION 1, ARTICLE III OF THE
CONSTITUTION, SPECIFICALLY THE “EQUAL PROTECTION CLAUSE.”11
Petitioner, on one hand, contends that, under Section 57 of Republic Act
(RA) 6657, otherwise known as the “Comprehensive Agrarian Reform Law”
(CARL), Special Agrarian Courts (SACs) were vested with limited criminal
jurisdiction, i.e., with respect only to the prosecution of all criminal offenses
under the said Act; that the only penal provision in RA 6657 is Section 73
thereof in relation to Section 74, which does not cover estafa; that no agrarian
reform law confers criminal jurisdiction upon the DARAB, as only civil and
administrative aspects in the implementation of the agrarian reform law have
been vested in the DAR; that necessarily, a criminal case for estafa instituted
against an agricultural tenant is within the jurisdiction and competence of regular
courts of justice as the same is provided for by law; that the cases relied upon
by the RTC do not find application in this case since the same were concerned
only with the civil and administrative aspects of agrarian reform implementation;
that there is no law which provides that agricultural tenants cannot be
prosecuted for estafa after they have misappropriated the lease rentals due the
landowners; and that to insulate agricultural tenants from criminal prosecution for
estafa would,
_______________
11 Rollo, pp. 4-5.
VOL. 559, JULY 21, 2008 241
People vs. Vanzuela
in effect, make them a class by themselves, which cannot be validly done
because there is no law allowing such classification. Petitioner submits that there
is no substantial distinction between an agricultural tenant who incurs criminal
liability for estafa for misappropriating the lease rentals due his landowner, and a
non-agricultural tenant who likewise incurs criminal liability for
misappropriation.12
Finally, petitioner posits that, at this point, it is premature to discuss the
merits of the case because the RTC has yet to receive in full the evidence of
both parties before it can render a decision on the merits. Petitioner also claims
that it is pointless to delve into the merits of the case at this stage, since the sole
basis of the assailed RTC Order is simply lack of jurisdiction.13
Respondents, on the other hand, argue that share tenancy is now
automatically converted into leasehold tenancy wherein one of the obligations of
an agricultural tenant is merely to pay rentals, not to deliver the landowner’s
share; thus, petitioner’s allegation that respondents misappropriated the
landowner’s share of the harvest is not tenable because share tenancy has
already been abolished by law for being contrary to public policy. Accordingly,
respondents contend that the agricultural tenant’s failure to pay his lease rentals
does not give rise to criminal liability for estafa. Respondents stand by the ruling
of the RTC that pursuant to Section 1, Rule II of the DARAB New Rules of
Procedure, the DARAB has jurisdiction over agrarian disputes; and that
respondents did not commit estafa for their alleged failure to pay their lease
rentals. Respondents submit that a simple case for ejectment and collection of
unpaid lease rentals, instead of a criminal case, should have been filed with the
DARAB. Respondents also submit that, assuming arguendo that they failed to
pay their lease rentals, they cannot be held liable for
_______________
12 Id., at pp. 5-8.
13 Petitioner’s Reply dated January 14, 2008; id., at pp. 45-51.
242 SUPREME COURT REPORTS ANNOTATED
People vs. Vanzuela
Estafa, as defined under Article 315, paragraph 4, No. 1(b) of the Revised
Penal Code, because the liability of an agricultural tenant is a mere monetary
civil obligation; and that an agricultural tenant who fails to pay the landowner
becomes merely a debtor, and, thus, cannot be held criminally liable for
estafa.14
Ostensibly, the main issue we must resolve is whether the RTC has
jurisdiction over the crime of estafa, because the assailed order is premised on
the RTC’s lack of jurisdiction over the subject matter. However, should our
resolution be in the affirmative, the more crucial issue is whether an agricultural
tenant, who fails to pay the rentals on the land tilled, can be successfully
prosecuted for estafa.
For the guidance of the bench and bar, we find it appropriate to reiterate the
doctrines laid down by this Court relative to the respective jurisdictions of the
RTC and the DARAB.
The three important requisites in order that a court may acquire criminal
jurisdiction are (1) the court must have jurisdiction over the subject matter; (2)
the court must have jurisdiction over the territory where the offense was
committed; and (3) the court must have jurisdiction over the person of the
accused.15
First. It is a well-entrenched doctrine that the jurisdiction of a tribunal over
the subject matter of an action is conferred by law. It is determined by the
material allegations of the complaint or information and the law at the time the
action was commenced. Lack of jurisdiction of the court over an action or the
subject matter of an action, cannot be cured by the silence, acquiescence, or
even by express consent of the parties. Thus, the jurisdiction of the court over
the nature of
_______________
14 Respondents’ Comment dated September 17, 2007; id., at pp. 43-47.
15 Cruz v. Court of Appeals, 436 Phil. 641, 654; 388 SCRA 72, 83 (2002), citing Oscar M.
Herrera, Remedial Law, Volume IV, 1992 Edition, p. 3.
VOL. 559, JULY 21, 2008 243
People vs. Vanzuela
the action and the subject matter thereof cannot be made to depend upon the
defenses set up in the court or upon a motion to dismiss; otherwise, the question
of jurisdiction would depend almost entirely on the defendant. Once jurisdiction
is vested, the same is retained up to the end of the litigation.16
In the instant case, the RTC has jurisdiction over the subject matter because
the law confers on it the power to hear and decide cases involving estafa. In
Arnado v. Buban,17 we held that:
“Under Article 315 of the Revised Penal Code, “the penalty of prision
correccional in its maximum period to prision mayor in its minimum period shall be
imposed if the amount of the fraud is over P12,000.00 but does not exceed
P22,000.00; and if such amount exceeds the latter sum, the penalty provided x x x
shall be imposed in its maximum period, adding one (1) year for its additional
P10,000.00 x x x.” Prision mayor in its minimum period, ranges from six (6) years
and one (1) day to eight (8) years. Under the law, the jurisdiction of municipal trial
courts is confined to offenses punishable by imprisonment not exceeding six (6)
years, irrespective of the amount of the fine.
Hence, jurisdiction over the criminal cases against the [respondents] pertains to
the regional trial court. x x x”
The allegations in the Information are clear—Criminal Case No. 6087
involves alleged misappropriation of the amount of P80,000.00.
_______________
16 Laresma v. Abellana, G.R. No. 140973, November 11, 2004, 442 SCRA 156, 168.
17 A.M. No. MTJ-04-1543, May 31, 2004, 430 SCRA 382, 387, citing Republic Act No.
7691, An Act Expanding the Jurisdiction of the Metropolitan Trial Courts, Municipal Trial
Courts, and Municipal Circuit Trial Courts, Amending for the Purpose Batas Pambansa
Blg. 129, otherwise known as the “Judiciary Reorganization Act of 1980.”
244 SUPREME COURT REPORTS ANNOTATED
People vs. Vanzuela
Second. The RTC also has jurisdiction over the offense charged since the
crime was committed within its territorial jurisdiction.
Third. The RTC likewise acquired jurisdiction over the persons of the
respondents because they voluntarily submitted to the RTC’s authority. Where
the court has jurisdiction over the subject matter and over the person of the
accused, and the crime was committed within its territorial jurisdiction, the court
necessarily exercises jurisdiction over all issues that the law requires the court to
resolve.18
Thus, based on the law and material allegations of the information filed, the
RTC erroneously concluded that it lacks jurisdiction over the subject matter on
the premise that the case before it is purely an agrarian dispute. The cases relied
upon by the RTC, namely, David v. Rivera19 and Philippine Veterans Bank
v. Court of Appeals,20 are of different factual settings. They hinged on the
subject matter of Ejectment and Annulment of Certificate of Land Ownership
Awards (CLOAs), respectively. It is true that in Machete v. Court of
Appeals21 this Court held that RTCs have no jurisdiction over cases for
collection of back rentals filed against agricultural tenants by their landowners. In
that case, however, what the landowner filed before the RTC was a collection
suit against his alleged tenants. These three cases show that trial courts were
declared to have no jurisdiction over civil cases which were initially filed with
them but were later on characterized as agrarian disputes and thus, within
DARAB’s jurisdiction. No such declaration has been made by this Court with
respect to criminal cases.
_______________
18 Cruz v. Court of Appeals, supra note 15.
19 Supra note 9.
20 Supra note 10.
21 320 Phil. 227, 235; 250 SCRA 176 (1995).
VOL. 559, JULY 21, 2008 245
People vs. Vanzuela
Instead, we have Monsanto v. Zerna,22 where we upheld the RTC’s
jurisdiction to try the private respondents, who claimed to be tenants, for the
crime of qualified theft. However, we stressed therein that the trial court cannot
adjudge civil matters that are beyond its competence. Accordingly, the RTC
had to confine itself to the determination of whether private respondents were
guilty of the crime. Thus, while a court may have authority to pass upon the
criminal liability of the accused, it cannot make any civil awards that relate to the
agrarian relationship of the parties because this matter is beyond its jurisdiction
and, correlatively, within DARAB’s exclusive domain.
In the instant case, the RTC failed to consider that what is lodged before it is
a criminal case for estafa involving an alleged misappropriated amount of
P80,000.00—a subject matter over which the RTC clearly has jurisdiction.
Notably, while the RTC has criminal jurisdiction conferred on it by law, the
DARAB, on the other hand, has no authority to try criminal cases at all. In
Bautista v. Mag-isa Vda. de Villena,23 we outlined the jurisdiction of the
DARAB, to wit:
“For agrarian reform cases, jurisdiction is vested in the Department of Agrarian
Reform (DAR); more specifically, in the Department of Agrarian Reform
Adjudication Board (DARAB).
Executive Order 229 vested the DAR with (1) quasi-judicial powers to determine
and adjudicate agrarian reform matters; and (2) jurisdiction over all matters involving
the implementation of agrarian reform, except those falling under the exclusive
original jurisdiction of the Department of Agriculture and the Department of
Environment and Natural Resources. This law divested the regional trial courts of
their general jurisdiction to try agrarian reform matters.
Under Republic Act 6657, the DAR retains jurisdiction over all agrarian reform
matters. The pertinent provision reads:
_______________
22 423 Phil. 150, 164; 371 SCRA 664 (2001).
23 G.R. No. 152564, Sep tember 13, 2004, 438 SCRA 259, 262-263. (Citations omitted).
246 SUPREME COURT REPORTS ANNOTATED
People vs. Vanzuela
Section 50. Quasi-Judicial Powers of the DAR.—The DAR is hereby
vested with the primary jurisdiction to determine and adjudicate agrarian
reform matters and shall have exclusive original jurisdiction over all matters
involving the implementation of agrarian reform, except those falling under
the exclusive jurisdiction of the Department of Agriculture and the
Department of Environment and Natural Resources.
It shall not be bound by technical rules of procedure and evidence but
shall proceed to hear and decide all cases, disputes or controversies in a most
expeditious manner, employing all reasonable means to ascertain the facts of
every case in accordance with justice and equity and the merits of the case.
Toward this end, it shall adopt a uniform rule of procedure to achieve a just,
expeditious and inexpensive determination of every action or proceeding
before it.
x x x x x x x x x”
Subsequently, in the process of reorganizing and strengthening the DAR,
Executive Order No. 129-A24 was issued; it created the DARAB to assume
the adjudicatory powers and functions of the DAR. Pertinent provisions of Rule
II of the DARAB 2003 Rules of Procedure read:
“SECTION 1. Primary and Exclusive Original Jurisdiction.—The Adjudicator
shall have primary and exclusive original jurisdiction to determine and adjudicate the
following cases:
1.1. The rights and obligations of persons, whether natural or juridical,
engaged in the management, cultivation, and use of all agricultural lands
covered by Republic Act (RA) No. 6657, otherwise known as the
Comprehensive Agrarian Reform Law (CARL), and other related agrarian
laws;
x x x x x x x x x
1.4. Those cases involving the ejectment and dispossession of tenants
and/or leaseholders;
x x x x x x x x x.
_______________
24 “Reorganizing and Strengthening the Department of Agrarian Reform and for Other
Purposes.” Approved on July 26, 1987.
VOL. 559, JULY 21, 2008 247
People vs. Vanzuela
Section 3(d) of RA 6657, or the CARL, defines an “agrarian dispute” over
which the DARAB has exclusive original jurisdiction as:
“(d) . . . refer[ing] to any controversy relating to tenurial arrangements,
whether leasehold, tenancy, stewardship or otherwise, over lands devoted to
agriculture, including disputes concerning farmworkers associations or
representation of persons in negotiating, fixing, maintaining, changing or seeking to
arrange terms or conditions of such tenurial arrangements
including
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.”25
Clearly, the law and the DARAB Rules are deafeningly silent on the
conferment of any criminal jurisdiction in favor of the DARAB. It is worth
stressing that even the jurisdiction over the prosecution of criminal offenses in
violation of RA 6657 per se is lodged with the SACs and not with the
DARAB.26 While indeed, the parties admit that there is an agricultural tenancy
relationship in this case, and that under the circumstances, Veneranda as
landowner could have simply filed a case before the DARAB for collection of
lease rentals
_______________
25 As cited in Sindico v. Diaz, G.R. No. 147444, October 1, 2004, 440 SCRA 50, 53-54.
26 Regional Trial Courts have not been completely divested of jurisdiction over
agrarian reform matters. §56 of RA 6657 confers jurisdiction on “Special Agrarian Courts,”
which are RTCs designated by this Court to act as such—at least one branch within each
province. Under §57, these special agrarian courts have original and exclusive jurisdiction
over (1) all petitions for the determination of just compensation to landowners and (2) the
prosecution of all criminal offenses under the Act.
248 SUPREME COURT REPORTS ANNOTATED
People vs. Vanzuela
and/or dispossession of respondents as tenants due to their failure to pay said
lease rentals, there is no law which prohibits landowners from instituting a
criminal case for estafa, as defined and penalized under Article 315 of the
Revised Penal Code, against their tenants. Succinctly put, though the matter
before us apparently presents an agrarian dispute, the RTC cannot shirk from its
duty to adjudicate on the merits a criminal case initially filed before it, based on
the law and evidence presented, in order to determine whether an accused is
guilty beyond reasonable doubt of the crime charged.
However, we must reiterate our ruling in Re: Conviction of Judge
Adoracion G. Angeles,27 that while we do not begrudge a party’s prerogative
to initiate a case against those who, in his opinion, may have wronged him, we
now remind landowners that such prerogative of instituting a criminal case
against their tenants, on matters related to an agrarian dispute, must be
exercised with prudence, when there are clearly lawful grounds, and only in the
pursuit of truth and justice.
Thus, even as we uphold the jurisdiction of the RTC over the subject matter
of the instant criminal case, we still deny the petition.
Herein respondents were charged with the crime of estafa as defined under
Article 315, paragraph 4, No. 1(b) of the Revised Penal Code, which refers to
fraud committed—
“By misappropriating or converting, to the prejudice of another, money, goods, or
any other personal property received by the offender in trust or on commission, or
for administration, or under any other obligation involving the duty to make delivery
of or to return the same, even though such obligation be totally or partially
guaranteed by a bond; or by denying having received such money, goods, or other
property.”
_______________
27 A.M. No. 06-9-545-RTC, January 31, 2008, 543 SCRA 196, 219.
VOL. 559, JULY 21, 2008 249
People vs. Vanzuela
We viewed the cases invoked by the petitioner, namely, People v.
Carulasdulasan and Becarel28 and Embuscado v. People29 where this Court
affirmed the conviction for estafa of the accused therein who were also
agricultural tenants. In People v. Carulasdulasan and Becarel,30 this Court
held that—
“From the facts alleged, it is clear that the accused received from the sale of the
abaca harvested by them a sum of money which did not all belong to them because
one-half of it corresponds to the landlord’s share of the abaca under the
tenancy agreement. This half the accused were under obligation to deliver to
the landlord. They therefore held it in trust for him. But instead of turning it
over to him, they appropriated it to their own use and refused to give it to him
notwithstanding repeated demands. In other words, the accused are charged with
having committed fraud by misappropriating or converting to the prejudice of
another money received by them in trust or under circumstances which made it their
duty to deliver it to its owner. Obviously, this is a form of fraud specially covered by
the penal provision above cited.”
In Embuscado v. People,31 the accused appealed to this Court his
conviction for the crime of theft by the Court of First Instance even as the
information charged him with Estafa and of which he was convicted by the City
Court. This Court ruled that the accused was denied due process when the
Court of First Instance convicted him of a crime not charged in the information,
and then reinstated with modification the ruling of the City Court convicting him
of estafa.
Unfortunately for the petitioner, these cited cases are inapplicable. People v.
Carulasdulasan and Becare32 involved a relationship of agricultural share
tenancy between the landowner and the accused. In such relationship, it was
incum-
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28 95 Phil. 8 (1954).
29 G.R. No. 38984, November 24, 1989, 179 SCRA 589.
30 Supra note 28 at 9-10 (Emphasis supplied).
31 Supra note 29.
32 Supra note 28.
250 SUPREME COURT REPORTS ANNOTATED
People vs. Vanzuela
bent upon the tenant to hold in trust and, eventually, account for the share in the
harvest appertaining to the landowner, failing which the tenant could be held
liable for misappropriation. As correctly pointed out by the respondents, share
tenancy has been outlawed for being contrary to public policy as early as 1963,
with the passage of R.A. 3844.33 What prevails today, under R.A. 6657, is
agricultural leasehold tenancy relationship, and all instances of share tenancy
have been automatically converted into leasehold tenancy. In such a relationship,
the tenant’s obligation is simply to pay rentals, not to deliver the landowner’s
share. Given this dispensation, the petitioner’s allegation that the respondents
misappropriated the landowner’s share of the harvest—as contained in the
information—is untenable. Accordingly, the respondents cannot be held liable
under Article 315, paragraph 4, No. 1(b) of the Revised Penal Code.
It is also worth mentioning that in Embuscado v. People,34 this Court
merely dwelt on the issue of whether the accused charged with estafa could be
convicted of the crime of theft. Issues of tenancy vis-à-vis issues of criminal
liability of tenants were not addressed. Thus, the dissenting opinion of then
Justice Teodoro R. Padilla in the said case is worth mentioning when he opined
that:
“It is also my opinion that the petitioner cannot be found guilty of estafa because the
mangoes allegedly misappropriated by him were not given to him in trust or on
commission, or for administration, or under any obligation involving the duty to
make delivery of, or to return the same, as provided for in Art. 315, par. 4, No. 1(b)
of the Revised Penal Code. What was entrusted to him for cultivation was a
landholding planted with coconut and mango trees and the mangoes, allegedly
misappropriated by him, were the fruits of the trees planted on the land.
Consequently, the action, if any, should have
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33 Also known as “The Agricultural Land Reform Code,” ap p roved on August 8, 1963.
34 Supra note 29.
VOL. 559, JULY 21, 2008 251
People vs. Vanzuela
been for accounting and delivery of the landlord’s share in the mangoes sold by the
petitioner.”35
In fine, we hold that the trial court erred when it dismissed the criminal case
for lack of jurisdiction over the subject matter. However, we find no necessity
to remand the case to the trial court for further proceedings, as it would only
further delay the resolution of this case. We have opted to rule on the merits of
the parties’ contentions, and hereby declare that respondents cannot be held
liable for estafa for their failure to pay the rental on the agricultural land subject
of the leasehold.
WHEREFORE, the petition is DENIED. No costs.
SO ORDERED.
Quisumbing,** Ynares-Santiago (Chairperson), Austria-Martinez and
Reyes, JJ., concur.
Petition denied.
Notes.—Settled is the rule that the jurisdiction of the court is determined by
the relevant allegations in the complaint and the character of the relief sought.
(General Milling Corporation vs. Uytengsu III, 494 SCRA 241 [2006])
It is clear from Sec. 57 that the RTC sitting as a Special Agrarian Court has
original and exclusive jurisdiction over all petitions for the determination of just
compensation to landowners. (Land Bank of the Philippines vs. Celada, 479
SCRA 495 [2006])
——o0o——
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35 Id., at p. 592.
** In lieu of Associate Justice Minita V. Chico-Nazario, per Special Order No. 508 dated
June 25, 2008.
