UNION BANK OF THE PHILIPPINES, petitioner vs. THE HON. REGIONAL AGRARIAN REFORM OFFICER, MIGUEL L. CARASOCHO, et al.
G.R. No. 203330-31/G.R. No. 200369
March 1, 2017
“Section 3 of the Comprehensive Agrarian Reform Law (CARL) defines an Agrarian Dispute as any controversy relating to tenurial arrangements, whether leasehold, tenancy, stewardship or otherwise, over lands devoted to agriculture. Given the technical legal meaning of the term ‘agrarian dispute’, it follows that not all cases involving agricultural lands automatically fall within the jurisdiction of the PARAD and DARAB.”
FACTS:
That covered by TCT No. T-137846 and T-156610 having areas of 1,083,250 sq.m. and 260,132 sq.m., respectively, located in Brgy. Bunggo, Calamba, Laguna, a land duly owned by the Union Bank of the Philippines as petitioner.
That the petitioner offered these parcels of land to DAR through the Voluntary Offer to Sell (VOS) arrangement under Comprehensive Agrarian Reform Program (CARP) of the government wherein after inspection of properties by DAR and LBP, a just compensation amounting to P2,230,699.30 and P716,672.35 offered by DAR.
That the DAR started issuing CLOAs in the name of private respondents as Agrarian Reform beneficiaries for the land covered by TCT No. T-156610 in which DAR MARO and PARO transmitted CLOAs to the Register of Deeds of Calamba for registration, while the TCT No. T-137846 was transferred to the Republic of the Philippines.
That the petitioner filed a Motion to withdraw Voluntary Offer to Sell on property from CARP Coverage in the land valuation proceedings for the land covered by TCT No. T-156610 pending before the Regional Agrarian Reform Adjudicator (RARAD).
That there were series of appeals of petitioner to PARAD, DARAB and to Court of Appeals until reached the Supreme Court which lead to the final decision of the case.
ISSUE:
1. Whether the Department of Agrarian Reform Adjudication Board (DARAB) has jurisdiction over petitions for cancellation of Certificates of Land Ownership Award (CLOAs) involving parties who do not have a tenancy relationship.
2. Whether the factual findings of Secretary of Agrarian Reform can be questioned in a petition for review on certiorari.
HELD:
On Issue 1:
No. The Department of Agrarian Reform Adjudication Board (DARAB) has “no” jurisdiction over petitions for cancellation of Certificates of Land Ownership Award (CLOAs) involving parties who do not have a tenancy relationship.
For the DARAB to have jurisdiction in cases involving cancellation of the CLOAs there must be an Agrarian Dispute between landowner and tenants who are recipients of the CLOAs. In this case, the record presented by the petitioner is bereft of any evidence showing that the petitioner and private respondents agrarian reform beneficiaries had tenancy relations.
For DARAB to acquire jurisdiction over the Case, there must be a prima facie showing that there is a tenurial arrangement or tenancy relationship between the parties. The records clearly show that the petitions filed by Union Bank did not involve agrarian disputes. The jurisdiction conferred to the DARAB is limited to agrarian disputes, which is subject to the precondition that there exist tenancy relations between the parties. This delineation applies in connection with cancellation of the CLOAs.
The jurisdiction of a court over the nature and subject matter of an action is conferred by law. In the course of Executive Order No. 129-A, the power to adjudicate agrarian reform cases was transferred to the DARAB, and the jurisdiction over the implementation of agrarian reform was delegated to the DAR regional offices. In consistent with the DARAB Rules of Procedures, the agrarian reform cases that fall within the jurisdiction of the PARAD and DARAB are those that involve agrarian disputes.
On Issue 2:
NO. The factual findings of Secretary of agrarian reform “cannot” be questioned in a petition for review on certiorari.
Section 50 of the CARL and Section 17 of EO No. 229 vested upon the DAR primary jurisdiction to determine and adjudicate agrarian reform matters, as well as original jurisdiction over all matters involving the implementation of agrarian reform. Thus, factual findings of administrative agencies are generally accorded respect and even finality the Supreme Court, especially when these findings are affirmed by the Court of Appeals.
WHEREFORE, the petitions are DENIED. The Decision dated November 18, 2011 and Resolution dated January 27, 2012 of the Court of Appeals-Special Twelfth Division in CA-G.R. SP No. 116106, and the Decision dated October 21, 2011 and Resolution dated August 30, 2012 of the Court of Appeals-Fifteenth Division in CA-G.R. SP Nos. 114159 and 114354 are AFFIRMED.
SO ORDERED.
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