Lawyerly

GR No. 176020

2014-09-29

HEIRS OF TELESFORO JULAO v. SPS. ALEJANDRO

DEL CASTILLO, J.

Jurisdiction over the subject matter is conferred by law and is determined by the material allegations of the complaint.[1] Thus, it cannot be acquired through, or waived by, any act or omission of the parties;[2] nor can it be cured by their silence, acquiescence, or even express consent.[3]

GR No. 189570

2013-07-31

HEIRS OF SANTIAGO NISPEROS v. MARISSA NISPEROS-DUCUSIN

VILLARAMA, JR., J.

It is axiomatic that the jurisdiction of a tribunal, including a quasi-judicial officer 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 for, irrespective of whether the petitioner or complainant is entitled to any or all such reliefs. Jurisdiction over the nature and subject matter of an action is conferred by the Constitution and the law, and not by the consent or waiver of the parties where the court otherwise would have no jurisdiction over the nature or subject matter of the action. Nor can it be acquired through, or waived by, any act or omission of the parties. Moreover, estoppel does not apply to confer jurisdiction to a tribunal that has none over the cause of action. The failure of the parties to challenge the jurisdiction of the DARAB does not prevent the court from addressing the issue, especially where the DARAB's lack of jurisdiction is apparent on the face of the complaint or petition.[27]

GR No. 191660

2012-12-03

DELIA T. SUTTON v. ROMANITO P. LIM

PERLAS-BERNABE, J.

While the DARAB may entertain petitions for cancellation of CLOAs, as in this case, its jurisdiction is, however, confined only to agrarian disputes. As explained in the case of Heirs of Dela Cruz v. Heirs of Cruz[16] and reiterated in the recent case of Bagongahasa v. Spouses Cesar Caguin,[17] for the DARAB to acquire jurisdiction, the controversy must relate to an agrarian dispute between the landowners and tenants in whose favor CLOAs have been issued by the DAR Secretary, to wit: The Court agrees with the petitioners' contention that, under Section 2(f), Rule II of the DARAB Rules of Procedure, the DARAB has jurisdiction over cases involving the issuance, correction and cancellation of CLOAs which were registered with the LRA. However, for the DARAB to have jurisdiction in such cases, they must relate to an agrarian dispute between landowner and tenants to whom CLOAs have been issued by the DAR Secretary. The cases involving the issuance, correction and cancellation of the CLOAs by the DAR in the administrative implementation of agrarian reform laws, rules and regulations to parties who are not agricultural tenants or lessees are within the jurisdiction of the DAR and not the DARAB. (Emphasis supplied)

GR No. 170251

2011-06-01

CELIA S. VDA. DE HERRERA v. EMELITA BERNARDO

PERALTA, J.

It is axiomatic that the jurisdiction of a tribunal, including a quasi-judicial officer 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 for, irrespective of whether the petitioner or complainant is entitled to any or all such reliefs.[10]

GR No. 180013

2011-01-31

DEL MONTE v. SANGUNAY

MENDOZA, J.

Where a question of jurisdiction between the DARAB and the Regional Trial Court is at the core of a dispute, basic jurisprudential tenets come into play. It is the rule that the jurisdiction of a tribunal, including a quasi-judicial office 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 for[20] irrespective of whether the petitioner or complainant is entitled to any or all such reliefs.[21] In the same vein, jurisdiction of the court over the subject matter of the action is not affected by the pleas or the theories set up by the defendant in an answer or a motion to dismiss. Otherwise, jurisdiction will become dependent almost entirely upon the whims of the defendant.[22]

GR No. 176530

2009-06-16

SPS. CONSTANTE AGBULOS AND ZENAIDA PADILLA AGBULOS v. NICASIO GUTIERREZ

CHICO-NAZARIO, J.

For the DARAB to have jurisdiction over a case, there must be a tenancy relationship between the parties. It is, therefore, essential to establish all the indispensable elements of a tenancy relationship, to wit: (1) that the parties are the landowner and the tenant or agricultural lessee; (2) that the subject matter of the relationship is an agricultural land; (3) that there is consent between the parties to the relationship; (4) that the purpose of the relationship is to bring about agricultural production; (5) that there is personal cultivation on the part of the tenant or agricultural lessee; and (6) that the harvest is shared between the landowner and the tenant or agricultural lessee.[14]

GR No. 147406

2008-07-14

VENANCIO FIGUEROA Y CERVANTES v. PEOPLE

NACHURA, J.

We note at this point that estoppel, being in the nature of a forfeiture, is not favored by law. It is to be applied rarely--only from necessity, and only in extraordinary circumstances. The doctrine must be applied with great care and the equity must be strong in its favor.[38] When misapplied, the doctrine of estoppel may be a most effective weapon for the accomplishment of injustice.[39] Moreover, a judgment rendered without jurisdiction over the subject matter is void.[40] Hence, the Revised Rules of Court provides for remedies in attacking judgments rendered by courts or tribunals that have no jurisdiction over the concerned cases. No laches will even attach when the judgment is null and void for want of jurisdiction.[41] As we have stated in Heirs of Julian Dela Cruz and Leonora Talaro v. Heirs of Alberto Cruz,[42]

GR No. 163285

2008-02-27

DEPARTMENT OF AGRARIAN REFORM v. HAKIM S. ABDULWAHID

PUNO, CJ.

It is the rule that the jurisdiction of a tribunal, including a quasi-judicial office 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 for, irrespective of whether the petitioner or complainant is entitled to any or all of such reliefs.[8] It is also settled that jurisdiction should be determined by considering not only the status or relationship of the parties but also the nature of the issues or questions that is the subject of the controversy.[9] Thus, if the issues between the parties are intertwined with the resolution of an issue within the exclusive jurisdiction of the DARAB, such dispute must be addressed and resolved by the DARAB.[10]

GR No. 162894

2008-02-26

RAYTHEON INTERNATIONAL v. STOCKTON W. ROUZIE

TINGA, J,

Jurisdiction over the nature and subject matter of an action is conferred by the Constitution and the law[30] and by the material allegations in the complaint, irrespective of whether or not the plaintiff is entitled to recover all or some of the claims or reliefs sought therein.[31] Civil Case No. 1192-BG is an action for damages arising from an alleged breach of contract. Undoubtedly, the nature of the action and the amount of damages prayed are within the jurisdiction of the RTC.

GR NO. 149095

2007-07-24

SONNY B. MANUEL v. DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD

AUSTRIA-MARTINEZ, J.

x x x x (Emphasis ours) Previously, however, E.O. No. 129-A[22] created the DARAB and authorized it to exercise said quasi-judicial powers,[23] to wit:Section 13. Agrarian Reform Adjudication Board - There is hereby created an Agrarian Reform Adjudication Board under the Office of the Secretary. The Board shall be composed of the Secretary as Chairman, two (2) Undersecretaries as may be designated by the Secretary, the Assistant Secretary for Legal Affairs and (3) others to be appointed by the President, upon the recommendation of the Secretary, as members. A Secretariat shall be constituted to support the Board. The Board shall assume the powers and functions with respect to the adjudication of agrarian reform cases under Executive Order No. 229 and this Executive Order. These powers and functions may be delegated to the regional offices of the Department in accordance with rules and regulations to be promulgated by the Board. (Emphasis ours) while it geared DAR primarily toward implementation of agrarian laws, thus:

GR NO. 154490

2006-09-19

SPS. ROMULO AND GUILLERMA CUBA v. MANUEL V. CUENCO

SANDOVAL-GUTIERREZ, J.

We agree with the Court of Appeals that indeed the jurisdiction of a tribunal, including a quasi-judicial agency, over the subject matter of a complaint or petition is determined by the allegations therein. However, in determining jurisdiction, it is not only the nature of the issues or questions that is the subject of the controversy that should be determined, but also the status or relationship of the parties.[6] Thus, if the issues between the parties are intertwined with the resolution of an issue within the exclusive jurisdiction of the DARAB, such dispute must be addressed and resolved by the DARAB.[7] Section 50 of Republic Act No. 6657[8] provides:SEC. 50. Quasi-Judicial Powers of the DAR. - The DAR is hereby vested with 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 (DA) and the Department of Environment and Natural Resources (DENR). (Underscoring supplied) In Vda. de Tangub v. Court of Appeals,[9] we held that the jurisdiction of the DAR concerns the (1) determination and adjudication of all matters involving implementation of agrarian reform; (2) resolution of agrarian conflicts and land-tenure related problems; and (3) approval or disapproval of the conversion, restructuring or readjustment of agricultural lands into residential, commercial, industrial, and other non-agricultural uses. The DAR, in turn, exercises this jurisdiction through its adjudicating arm, the DARAB.[10]

	GR No. 176020 2014-09-29	HEIRS OF TELESFORO JULAO v. SPS. ALEJANDRO DEL CASTILLO, J.
Jurisdiction over the subject matter is conferred by law and is determined by the material allegations of the complaint.[1] Thus, it cannot be acquired through, or waived by, any act or omission of the parties;[2] nor can it be cured by their silence, acquiescence, or even express consent.[3]
	GR No. 189570 2013-07-31	HEIRS OF SANTIAGO NISPEROS v. MARISSA NISPEROS-DUCUSIN VILLARAMA, JR., J.
It is axiomatic that the jurisdiction of a tribunal, including a quasi-judicial officer 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 for, irrespective of whether the petitioner or complainant is entitled to any or all such reliefs. Jurisdiction over the nature and subject matter of an action is conferred by the Constitution and the law, and not by the consent or waiver of the parties where the court otherwise would have no jurisdiction over the nature or subject matter of the action. Nor can it be acquired through, or waived by, any act or omission of the parties. Moreover, estoppel does not apply to confer jurisdiction to a tribunal that has none over the cause of action. The failure of the parties to challenge the jurisdiction of the DARAB does not prevent the court from addressing the issue, especially where the DARAB's lack of jurisdiction is apparent on the face of the complaint or petition.[27]
	GR No. 191660 2012-12-03	DELIA T. SUTTON v. ROMANITO P. LIM PERLAS-BERNABE, J.
While the DARAB may entertain petitions for cancellation of CLOAs, as in this case, its jurisdiction is, however, confined only to agrarian disputes. As explained in the case of Heirs of Dela Cruz v. Heirs of Cruz[16] and reiterated in the recent case of Bagongahasa v. Spouses Cesar Caguin,[17] for the DARAB to acquire jurisdiction, the controversy must relate to an agrarian dispute between the landowners and tenants in whose favor CLOAs have been issued by the DAR Secretary, to wit: The Court agrees with the petitioners' contention that, under Section 2(f), Rule II of the DARAB Rules of Procedure, the DARAB has jurisdiction over cases involving the issuance, correction and cancellation of CLOAs which were registered with the LRA. However, for the DARAB to have jurisdiction in such cases, they must relate to an agrarian dispute between landowner and tenants to whom CLOAs have been issued by the DAR Secretary. The cases involving the issuance, correction and cancellation of the CLOAs by the DAR in the administrative implementation of agrarian reform laws, rules and regulations to parties who are not agricultural tenants or lessees are within the jurisdiction of the DAR and not the DARAB. (Emphasis supplied)
	GR No. 170251 2011-06-01	CELIA S. VDA. DE HERRERA v. EMELITA BERNARDO PERALTA, J.
It is axiomatic that the jurisdiction of a tribunal, including a quasi-judicial officer 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 for, irrespective of whether the petitioner or complainant is entitled to any or all such reliefs.[10]
	GR No. 180013 2011-01-31	DEL MONTE v. SANGUNAY MENDOZA, J.
Where a question of jurisdiction between the DARAB and the Regional Trial Court is at the core of a dispute, basic jurisprudential tenets come into play. It is the rule that the jurisdiction of a tribunal, including a quasi-judicial office 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 for[20] irrespective of whether the petitioner or complainant is entitled to any or all such reliefs.[21] In the same vein, jurisdiction of the court over the subject matter of the action is not affected by the pleas or the theories set up by the defendant in an answer or a motion to dismiss. Otherwise, jurisdiction will become dependent almost entirely upon the whims of the defendant.[22]
	GR No. 176530 2009-06-16	SPS. CONSTANTE AGBULOS AND ZENAIDA PADILLA AGBULOS v. NICASIO GUTIERREZ CHICO-NAZARIO, J.
For the DARAB to have jurisdiction over a case, there must be a tenancy relationship between the parties. It is, therefore, essential to establish all the indispensable elements of a tenancy relationship, to wit: (1) that the parties are the landowner and the tenant or agricultural lessee; (2) that the subject matter of the relationship is an agricultural land; (3) that there is consent between the parties to the relationship; (4) that the purpose of the relationship is to bring about agricultural production; (5) that there is personal cultivation on the part of the tenant or agricultural lessee; and (6) that the harvest is shared between the landowner and the tenant or agricultural lessee.[14]
	GR No. 147406 2008-07-14	VENANCIO FIGUEROA Y CERVANTES v. PEOPLE NACHURA, J.
We note at this point that estoppel, being in the nature of a forfeiture, is not favored by law. It is to be applied rarely--only from necessity, and only in extraordinary circumstances. The doctrine must be applied with great care and the equity must be strong in its favor.[38] When misapplied, the doctrine of estoppel may be a most effective weapon for the accomplishment of injustice.[39] Moreover, a judgment rendered without jurisdiction over the subject matter is void.[40] Hence, the Revised Rules of Court provides for remedies in attacking judgments rendered by courts or tribunals that have no jurisdiction over the concerned cases. No laches will even attach when the judgment is null and void for want of jurisdiction.[41] As we have stated in Heirs of Julian Dela Cruz and Leonora Talaro v. Heirs of Alberto Cruz,[42]
	GR No. 163285 2008-02-27	DEPARTMENT OF AGRARIAN REFORM v. HAKIM S. ABDULWAHID PUNO, CJ.
It is the rule that the jurisdiction of a tribunal, including a quasi-judicial office 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 for, irrespective of whether the petitioner or complainant is entitled to any or all of such reliefs.[8] It is also settled that jurisdiction should be determined by considering not only the status or relationship of the parties but also the nature of the issues or questions that is the subject of the controversy.[9] Thus, if the issues between the parties are intertwined with the resolution of an issue within the exclusive jurisdiction of the DARAB, such dispute must be addressed and resolved by the DARAB.[10]
	GR No. 162894 2008-02-26	RAYTHEON INTERNATIONAL v. STOCKTON W. ROUZIE TINGA, J,
Jurisdiction over the nature and subject matter of an action is conferred by the Constitution and the law[30] and by the material allegations in the complaint, irrespective of whether or not the plaintiff is entitled to recover all or some of the claims or reliefs sought therein.[31] Civil Case No. 1192-BG is an action for damages arising from an alleged breach of contract. Undoubtedly, the nature of the action and the amount of damages prayed are within the jurisdiction of the RTC.
	GR NO. 149095 2007-07-24	SONNY B. MANUEL v. DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD AUSTRIA-MARTINEZ, J.
x x x x (Emphasis ours) Previously, however, E.O. No. 129-A[22] created the DARAB and authorized it to exercise said quasi-judicial powers,[23] to wit:Section 13. Agrarian Reform Adjudication Board - There is hereby created an Agrarian Reform Adjudication Board under the Office of the Secretary. The Board shall be composed of the Secretary as Chairman, two (2) Undersecretaries as may be designated by the Secretary, the Assistant Secretary for Legal Affairs and (3) others to be appointed by the President, upon the recommendation of the Secretary, as members. A Secretariat shall be constituted to support the Board. The Board shall assume the powers and functions with respect to the adjudication of agrarian reform cases under Executive Order No. 229 and this Executive Order. These powers and functions may be delegated to the regional offices of the Department in accordance with rules and regulations to be promulgated by the Board. (Emphasis ours) while it geared DAR primarily toward implementation of agrarian laws, thus:
	GR NO. 154490 2006-09-19	SPS. ROMULO AND GUILLERMA CUBA v. MANUEL V. CUENCO SANDOVAL-GUTIERREZ, J.
We agree with the Court of Appeals that indeed the jurisdiction of a tribunal, including a quasi-judicial agency, over the subject matter of a complaint or petition is determined by the allegations therein. However, in determining jurisdiction, it is not only the nature of the issues or questions that is the subject of the controversy that should be determined, but also the status or relationship of the parties.[6] Thus, if the issues between the parties are intertwined with the resolution of an issue within the exclusive jurisdiction of the DARAB, such dispute must be addressed and resolved by the DARAB.[7] Section 50 of Republic Act No. 6657[8] provides:SEC. 50. Quasi-Judicial Powers of the DAR. - The DAR is hereby vested with 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 (DA) and the Department of Environment and Natural Resources (DENR). (Underscoring supplied) In Vda. de Tangub v. Court of Appeals,[9] we held that the jurisdiction of the DAR concerns the (1) determination and adjudication of all matters involving implementation of agrarian reform; (2) resolution of agrarian conflicts and land-tenure related problems; and (3) approval or disapproval of the conversion, restructuring or readjustment of agricultural lands into residential, commercial, industrial, and other non-agricultural uses. The DAR, in turn, exercises this jurisdiction through its adjudicating arm, the DARAB.[10]

HEIRS OF JULIAN DELA CRUZ v. HEIRS OF ALBERTO CRUZ