Sta. Ana v.

Carpo
[G.R. No. 164340 November 28, 2008]
Nachura, J.:

Facts:
- Respondent Carpo owns a land 91,337 sqm land in Sta. Rosa Laguna. 3.5 hectares of which is
devoted for rice and corn production and was tenanted by Domigo and Adoracion Pastolero. When
Domingo passed away, Adoracion sold their tenancy rights to petitioner Sta. Ana, which conformity of
Leon, for P72,500.
- After some time, the relationship between the parties turned sour and the respondents filed an
ejectment case against the respondents due to Non-payment of lease rentals. Respondents alleged the
parties agreed to increase the rentals from 36 to 45 cavans, and that, if respondents wanted to
repossess the property, they only had to pay P72,500.00.
- Respondents further averred that despite repeated demands, petitioner refused to pay the actual
rentals; and that the subject land had been declared, suitable for commercial and industrial purposes,
per Zoning Ordinance of 1981 of the Municipality of Sta. Rosa, Laguna. Respondents prayed that
petitioner be ejected from the subject land and be directed to pay P75,016.00 as unpaid rentals.
- Petitioner denied that there was an agreement to increase the rental and that they did not refuse to pay
the respondents, stating further that they even sent out notices advising the respondents to accept; and
that petitioners even deposited the amounts to Universal Savings Bank. They further claim that
petitioner is a farmer-beneficiary of P.D. 27 and prayed for outright dismissal of the case
- PARAD ruled that petitioner deliberately failed defaulted the payment to the respondents. It was also
shown that the petitioners deposited the amounts in their names and not the respondents. PARAD also
ruled that the defendant is not covered by P.D. 27 since it needed at least 7 hectares devoted to palay
- DARAB, however, reversed the ruling of PARAD, stating that there was no proof that the failure to pay
the rentals by the petitioner was willful and deliberate
- The CA once again reversed the ruling to the DARAB stating that petitioners failed to pay the rentals.
Further, CA held that subject land was not covered by P.D. 27 since it has become residential,
commercial, and industrial. Thus, it ruled in favor of the respondents

Issue:
- WON the CA erred in ruling that the subject land had already become residential, commercial and/or
industrial, thus, excluded from the coverage of our laws on agrarian reform; and
- WON the petitioner deliberately failed to pay her lease rentals when the same fell due

Held:
- The court first dealt with the procedural issue that Petitioner to file the petition 1 day in excess of that
which is required. However, the court has made this case and exemption in order to meet the ends of
justice
- In the first issue, the court ruled in affirmative. It was held that the PARAD acted without jurisdiction
when it held that the subject land was no longer covered by our agrarian laws because of the retention
rights of the respondents. The CA likewise acted without jurisdiction when it ruled that the land had
become non-agricultural based on a zoning ordinance of 1981 on the strength of a mere vicinity map.
These rulings violated the doctrine of primary jurisdiction.
- The doctrine of primary jurisdiction precludes the courts from resolving a controversy over which
jurisdiction has initially been lodged in an administrative body of special competence. For agrarian
reform cases, jurisdiction is vested in the DAR; more specifically, DARAB
- CA ruled that the land had ceased being agricultural on the basis of a mere vicinity map, in open
disregard of the Doctrine of Primary Jurisdiction, since the issue was within the province of the
Secretary of DAR
- On the second issue, the SC ruled in the Negative. Under Sec. 37 of R.A. 3844, coupled with the fact
that the respondents are the complainants themselves, the burden of proof to show the existence of a
lawful cause for the ejectment of the petitioner as an agricultural lessee rests upon the respondents as
agricultural lessors. However, the respondents failed to discharge such burden.