G.R. No. 154286 . February 28, 2006.
MAGDALENA CORUÑA, ET AL., Petitioners, vs. SATURNINO CINAMIN, ET AL., Respondents.

FACTS

Petitioners are the co-owners of two parcels of land inherited from their mother. They filed two complaints before the Provincial Agrarian Reform Adjudicator (PARAD) seeking the cancellation of Emancipation Patents (EPs) and Certificates of Land Transfer (CLTs) issued to respondents. Petitioners argued that the lands were primarily devoted to sugar, with only small portions for rice and corn. They claimed that as co-owners, each one’s share in the rice and corn areas was below the seven-hectare retention limit under Presidential Decree No. 27, making the compulsory coverage and issuance of EPs invalid. They further alleged that respondents were not their bona fide tenants and had failed to pay lease rentals and amortizations.
Respondents countered that they and their predecessors-in-interest were legitimate tenants who had been paying the landowners’ shares. They were duly identified by the Department of Agrarian Reform (DAR) as farmer-beneficiaries under P.D. No. 27. They asserted that they had been paying amortizations through the Land Bank of the Philippines and real property taxes. The PARAD dismissed the complaints, finding that respondents had sufficiently proven the existence of a tenancy relationship. This decision was affirmed by the DAR Adjudication Board (DARAB) and subsequently by the Court of Appeals.

ISSUE

Whether the Court of Appeals erred in affirming the dismissal of the complaints and upholding the validity of the Emancipation Patents issued to the respondents.

RULING

The Supreme Court denied the petition and affirmed the assailed decisions. The legal logic is anchored on the conclusive nature of an Emancipation Patent once registered. Citing jurisprudence, the Court held that the issuance of an EP, and the subsequent issuance of an Original Certificate of Title upon its registration, places the land covered beyond the regulatory authority of the DAR. The EP becomes the conclusive evidence of ownership, and any challenge to its validity must be directed to the regular courts in an action expressly instituted for that purpose. The DARAB, being a quasi-judicial body with limited jurisdiction, loses authority over the land once title is registered in the beneficiary’s name.
The Court found that the EPs and CLTs in question had been registered, and Original Certificates of Title had been issued to the respondents. Consequently, the DARAB correctly dismissed the complaints for lack of jurisdiction. Petitioners’ proper recourse was an action for annulment of title or reconveyance in the regular courts, not a cancellation proceeding before the agrarian tribunals. The Court also noted that petitioners failed to substantiate their claim regarding the land’s primary crop with sufficient evidence, while respondents adequately established their status as identified farmer-beneficiaries.