GR 269362; (April, 2025) (Digest)
G.R. No. 269362 , April 07, 2025
HEIRS OF SPOUSES ADRIANO SALISE AND NATIVIDAD PAGUDAR, ET AL., PETITIONERS, VS. RICARDO A. GACULA, RESPONDENT.
FACTS
Respondent Ricardo Gacula filed a Petition for Cancellation of the petitioners’ Certificates of Land Ownership Award (CLOAs) before the DARAB. The Provincial Adjudicator dismissed it without prejudice due to Gacula’s pending Application for Exemption of the land from CARP coverage. Gacula appealed this dismissal. Meanwhile, the DAR Secretary granted his Application for Exemption, a decision later reversed and then reinstated upon motions for reconsideration, ultimately becoming final in 2001. Concurrently, the DARAB Central Office dismissed Gacula’s appeal of the cancellation petition.
Despite this dismissal, Gacula filed a Manifestation before the DARAB Regional Adjudicator, requesting implementation of the DAR Secretary’s final exemption order. Acting thereon, the Adjudicator issued an Order cancelling the petitioners’ CLOAs and a Writ of Execution. The petitioners appealed this Order to the DARAB Central Office, which ruled in their favor, finding the Adjudicator had no jurisdiction to cancel CLOAs based solely on an exemption order from the DAR Secretary. The Court of Appeals reversed the DARAB, reinstating the Adjudicator’s cancellation order.
ISSUE
Whether the DARAB Adjudicator had jurisdiction to cancel the petitioners’ CLOAs based on the DAR Secretary’s final order exempting the land from CARP coverage.
RULING
No. The Supreme Court reversed the Court of Appeals and reinstated the DARAB Decision. The legal logic hinges on the distinct jurisdictions of the DAR Secretary and the DARAB. The authority to exempt land from CARP coverage is an executive function vested exclusively in the DAR Secretary. Conversely, the DARAB is a quasi-judicial body with jurisdiction over agrarian disputes, including the cancellation of CLOAs issued under the agrarian reform program.
The DAR Secretary’s final order of exemption merely declared the land outside CARP coverage. It did not, and could not, automatically cancel the CLOAs already issued. The cancellation of a CLOA is a judicial or quasi-judicial function that requires a separate proceeding where the rights of the awardees are heard and adjudicated. The Regional Adjudicator gravely abused his discretion by treating the Secretary’s exemption order as a direct mandate to cancel the CLOAs. His November 2003 Order was a nullity for having been issued without jurisdiction. The proper course was for Gacula to file a new petition for cancellation before the DARAB, where the petitioners could contest the cancellation on substantive grounds, not for the Adjudicator to execute the exemption order as if it were a judgment.