G.R. No. 149095 ; July 24, 2007
SONNY B. MANUEL, Petitioner, vs. DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD (DARAB) and PEDRO TEJADA, Respondents.

FACTS

A portion of the Cojuangco estate was placed under Operation Land Transfer and an Emancipation Patent (EP) was issued to respondent Pedro Tejada in 1987. In 1996, petitioner Sonny B. Manuel filed a petition before the Provincial Agrarian Reform Adjudication Board (PARAB) seeking the cancellation of Tejada’s EP and the issuance of a new one in his name. Manuel presented an “Affidavit of Voluntary Surrender” allegedly executed by Tejada, a Samahang Nayon resolution recommending him as beneficiary, and certifications showing he had been cultivating the land and paying the amortizations since 1987. Tejada opposed, claiming he only mortgaged the property to Manuel and did not execute the affidavit.
The PARAB granted Manuel’s petition, ordering the cancellation of Tejada’s EP and the issuance of a new one to Manuel. On appeal, the DARAB affirmed the cancellation of Tejada’s EP but disqualified Manuel as a new beneficiary, finding he was a government engineer working elsewhere, which contradicted the policy of awarding land to actual tillers. The Court of Appeals affirmed the DARAB’s decision, adding that Manuel’s employment and residence elsewhere constituted abandonment of the landholding.

ISSUE

Whether the DARAB, in the exercise of its quasi-judicial jurisdiction over an application for an emancipation patent, may inquire into and reverse the administrative finding of the DAR on the qualification of an agrarian reform beneficiary.

RULING

The Supreme Court granted the petition, ruling that the DARAB exceeded its jurisdiction. The Court delineated the separate powers of the Department of Agrarian Reform (DAR) and the DARAB. The DAR, through its Secretary, possesses primary and exclusive jurisdiction over agrarian law implementation (ALI) cases, which include the identification, qualification, or disqualification of potential farmer-beneficiaries. This is an administrative function. Conversely, the DARAB is a quasi-judicial body tasked with adjudicating agrarian reform matters, such as disputes involving tenurial rights. The determination of a beneficiary’s qualification is an ALI function falling squarely within the DAR Secretary’s domain, not the DARAB’s adjudicatory power.
In this case, the DARAB, by disqualifying Manuel as a beneficiary after the PARAB had granted his application based on DAR’s administrative processes and certifications, effectively reviewed and reversed an administrative determination. This was an encroachment upon the DAR Secretary’s exclusive authority. The proper course of action for the DARAB, upon finding Tejada’s EP voidable, was to cancel it and remand the matter to the DAR Secretary for the administrative re-allocation of the landholding to a qualified beneficiary. The DARAB’s decision to disqualify Manuel directly was therefore annulled and set aside for lack of jurisdiction.