People v.

Vanzuela,
G.R. No. 178266, July 21, 2008
Ratio:

Facts:

- The petitioner People of the Philippines (petitioner) seeks the reversal of the
Order 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).
- 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
- 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.
- 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 ₱80,000.00, did then and there willfully, unlawfully and feloniously
misappropriate, misapply and convert said sum of ₱80,000.00 to their own use
and benefit to the damage and prejudice of said Veneranda Paler and other heirs
of the late Dionesio Paler, Sr.
- 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.
- RTC dismissed the criminal case ratiocinating 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.
- Petitioner, on one hand, contends that, under Section 57 of Republic Act (RA)
6657, 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, 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.
- 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.
- 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 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.
- The three important requisites in order that a court may acquire criminal
jurisdiction are
- (1) the court must have jurisdiction over the subject matter; - conferred by
law, determined based on the material allegations of the complaint or
information and the law at the time the case was filed. Here RTC has
jurisdiction over subject matter. Since penalty exceeds 6 years RTC has
jurisdiction.
- (2) the court must have jurisdiction over the territory where the offense was
committed; and – venue is jurisdictional
- (3) the court must have jurisdiction over the person of the accused. – thru
arrest, whether with warrant or not, or thru voluntary submission of his person
to the court. The RTC likewise acquired jurisdiction over the persons of
the respondents because they voluntarily submitted to the RTC's
authority.
- 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. Rivera 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.
- 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
₱80,000.00 -- 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, 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).
- 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.
- 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.
- The court reiterated the ruling on Conviction of Judge Adoracion G. Angeles, 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.
- The court held that the cited cases of the petitioner is not applicable.
- People v. Carulasdulasan and Becare 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.
- 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.

- The court may conduct preliminary hearing whether tenurial