GR NO.

152086

FACTS:

The herein petitioners are tenants of the agricultural lands of the respondents. The respondents
entered into a compromised agreement with the petitioners that portions of the land of the
respondents which is untilled, will be used for building commercial establishments so that petiotners are
requested to relocate their houses on the same landholdings the site shall be determined by the
respondents. The compromise agreement was then binding between the parties. When respondents
started to construct the buildings and made signage that said business establishment is soon to arise,
the petitioners filed a complaint to the Municipal Agrarian Reform Officer contending that said land was
under the coverage of OLT program provided in the Tenants Emancipation Decree. MARO already ruled
that the subject properties are not covered by OLT. So the respondents prayed to DARAB that
petitioners be ordered to comply with compromised agreement in relocating their houses and instead
cultivated on the untilled portions of the land, pay the rentals for leasing the land, eject defendants
from the subject properties for failure to pay lease rentals and pay for the damages. The Petitioners, on
its claim, contended that they will not pay for the lease rentals until evidence of the titles of the land has
been proved. The CA affirmed the decision of the quasi-judicial bodies that the subject properties were
not under the coverage of OLT and that the petitioners are hereby ordered to relocate their homes
specified by the respondents and pay for the lease rentals and damages in favor of the respondents. The
petitioners now challenge the jurisdiction of the PARAD and DARAB as the issue involves title of the
subject land.

ISSUE: Whether or not the quasi-judicial bodies had jurisdiction over the case.
Whether or not the compromise agreement is valid.

HELD:

The Supreme Court upheld the decision of the lower adjudication courts and ruled that the
jurisdiction of a tribunal, including 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 complaint is entitled to any
or all such reliefs. Indeed, the jurisdiction of the court or tribunal is not affected by the defenses or
theories set up by the defendant or respondent in his answer or motion to dismiss.
As regards the issue of the validity and legality of the compromise agreement, the same does
not deserve a prolonged discussion. It is beyond question that the petitioners are bound by the said
compromise agreement. The document was entered into by and between the parties without any vice
of consent and was duly notarized. The compromise agreement is clearly a waiver of their rights over
the subject landholding for it contains admissions and declarations against their interest. If the
petitioners contend that it was not so, thus, reneging on their own sworn admissions of existence of the
fact, then they must have perjured themselves when they voluntarily and knowingly stated under oath
that they are relinquishing their right over the subject holding. The Board will not allow such perfidy to
prevail because a party to a litigation must always come to court with clean hands and in good faith.
Petitioners are bound by their own voluntary admissions and declarations against their own interest as
appearing in the said compromise agreement and the Board will not allow them to turn their backs to it.