GR 146035; (September, 2005) (Digest)
G.R. No. 146035 . September 9, 2005
ESPERANZA VDA. DE LOPEZ and MODESTA VDA. DE ASUNCION, Petitioners, vs. HON. COURT OF APPEALS and REYNALD M. ROMERO, Respondents.
FACTS
The case involves two agricultural lots in Pampanga. Originally awarded to farmer-beneficiary Leonardo Briones, the lots were later sold to respondent Reynald Romero, who obtained new CLOAs and titles. Petitioners Esperanza Vda. de Lopez and Modesta Vda. de Asuncion challenged Briones’s original award before the DAR Regional Office. In a separate proceeding, Briones petitioned the PARAB to cancel his CLOA, which was granted, facilitating the transfer to Romero. Subsequently, the DAR Regional Office issued an Order disqualifying Briones and later Romero, and awarding the lots to petitioners, directing them to seek cancellation of Romero’s CLOAs in the proper forum.
Romero then filed a petition with the PARAB for “Maintenance of Peaceful Possession and Annulment/Cancellation of Order dated December 13, 1995 with Injunction,” docketed as DARAB Case No. 4098 P’96. Petitioners moved to dismiss, arguing the PARAB lacked jurisdiction because the DAR Regional Office had already ruled on the matter. The PARAB denied the motion, a decision affirmed by the Court of Appeals, prompting this petition.
ISSUE
Whether the Provincial Agrarian Reform Adjudication Board (PARAB) has jurisdiction over DARAB Case No. 4098 P’96, which involves the cancellation of CLOAs and questions a DAR Regional Office Order.
RULING
Yes, the PARAB has jurisdiction. The Supreme Court affirmed the CA’s ruling, holding that under the DARAB’s New Rules of Procedure, the Adjudication Board has primary and exclusive original jurisdiction over cases involving the “issuance, correction and cancellation of Certificates of Land Ownership Award (CLOAs).” Romero’s petition before the PARAB essentially sought the annulment of the DAR Regional Director’s Order and the maintenance of his rights as a CLOA holder, matters falling squarely within the PARAB’s jurisdiction.
The Court clarified that the DAR Regional Office’s Order of December 13, 1995, which directed petitioners to institute an action for cancellation before the proper forum, was a void judgment for want of jurisdiction. A void judgment creates no rights or obligations and can never become final. The Regional Director himself recognized this lack of authority by explicitly directing the parties to the proper forum—the DARAB. Consequently, the PARAB correctly assumed jurisdiction over Romero’s petition. The Court declined to rule on the merits of the case, deferring to the PARAB as the proper adjudicatory body under the executive branch to resolve the substantive issues. The petition was denied.