PEOPLE V. VALENZUELA (CRIMINAL, REMEDIAL)

It is a well entrenched rule doctrine that 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 of 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 cannot be made to depend upon the defenses set up in the court or upon the a motion to dismiss; otherwise, the question of jurisdiction would depend almost entirely on the defendant. Ounce jurisdiction is vested, the same is retained up to the end of the litigation.

In the instant case, the RTC has the jurisdiction over the subject matter because the law confers on it the power to hear and decide cases involving estafa. The allegations are clear. the RTC also has jurisdiction over the offense charged since the crime was committed within its territorial jurisdiction. the RTC likewise acquired jurisdiction over the persons of the respondents because they voluntarily submitted to the RTC's authority.

When 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.

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. 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.

But even if we uphold the jurisdiction of the RTC over the subject matter of the instant criminal case, we still deny the petition.

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 RA 3844. What prevails today, under RA 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 for estafa under the Revised Penal Code.