G.R. No. 201631 , December 7, 2021
ANGELINA DAYRIT, REPRESENTED BY JULIE E. DAYRIT, PETITIONER, VS. JOSE I. NORQUILLAS, ET AL., RESPONDENTS.

FACTS

The lands subject of the dispute are covered by the government’s Comprehensive Agrarian Reform Program (CARP). As early as 1993, the petitioner’s Original Certificate of Title and Transfer Certificate of Title had been cancelled, and new titles pursuant to Certificates of Land Ownership Award (CLOAs) were issued to the respondents. The respondents occupied the property based on these CLOAs. The petitioner filed a forcible entry suit in the Municipal Circuit Trial Court. The Court of Appeals reversed the trial courts’ rulings, citing the primary jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB) over disputes relating to CARP implementation. The Court of Appeals noted that the issue of possession was linked to an agrarian dispute, as the respondents’ entry was based on the CLOAs awarded under CARP. Furthermore, there was a pending appeal before the DARAB concerning the cancellation of the CLOAs.

ISSUE

Whether the Department of Agrarian Reform Adjudication Board (DARAB), and not the regular courts, has jurisdiction over the forcible entry case, given that the dispute is inextricably connected to the implementation of the Comprehensive Agrarian Reform Program.

RULING

Yes. The DARAB has primary and exclusive original jurisdiction over the case. Republic Act No. 6657 (Comprehensive Agrarian Reform Law), as amended by Republic Act No. 9700 , vests the Department of Agrarian Reform (DAR) with primary jurisdiction to adjudicate agrarian reform matters. Section 50-A of the amended law provides that if there is an allegation that a case is agrarian in nature and involves a farmer, farmworker, or tenant, it shall be automatically referred to the DAR for determination. The facts establish that the possession dispute is inextricably linked to an agrarian dispute, as the respondents’ occupation stems from CLOAs issued under CARP, and the petitioner’s titles were cancelled pursuant to the program. The petitioner herself filed a petition before the DARAB over the same land and parties, implying the agrarian nature of the dispute. The pendency of the DARAB appeal concerning the CLOAs also meant a ruling in the ejectment case could result in conflicting decisions. The case of David v. Cordova is not controlling because it involved a situation where no agrarian dispute existed, unlike here. Therefore, jurisdiction properly lies with the DARAB.