GR 103953; (March, 1999) (Digest)
G.R. No. 103953 March 25, 1999
SAMAHANG MAGBUBUKID NG KAPDULA, INC., petitioner-appellant, vs. THE HONORABLE COURT OF APPEALS, PONCIANO DUCUSIN, et al., respondent-appellees.
FACTS
The subject agricultural lands, originally owned by Macario Aro and tenanted by petitioner’s members, were sold in 1979-1980. The subsequent owner failed to establish an assembly plant, and the lands were leased to spouses who developed a sugarcane plantation, employing private respondents as regular farmworkers. The Philippine National Bank later acquired the property at auction. In 1991, the Department of Agrarian Reform (DAR), after the land was transferred to the Republic, issued Certificates of Land Ownership Award (CLOAs) to the petitioner organization.
Private respondents, the current farmworkers, filed a petition for certiorari with the Court of Appeals, challenging the CLOA issuance. They alleged they were not afforded due process in the administrative proceedings that led to the award. The appellate court granted the petition, directing the DAR to conduct a new hearing with notice to private respondents to determine the rightful beneficiaries and to cancel the CLOAs if petitioner is found not entitled.
ISSUE
The core issues are: (1) whether private respondents were required to exhaust administrative remedies before filing the certiorari petition; and (2) whether due process was observed in the issuance of the CLOAs.
RULING
The Supreme Court affirmed the Court of Appeals. On the first issue, the Court ruled that exhaustion of administrative remedies was not mandatory. The determination of qualified beneficiaries by the DAR Secretary is a quasi-judicial function. A party aggrieved by such a determination may directly resort to judicial review via a petition for certiorari under Section 54 of Republic Act No. 6657 (Comprehensive Agrarian Reform Law), which allows appeals from DAR decisions to the Court of Appeals. The private respondents’ direct recourse was therefore proper.
On the second issue, the Court found a denial of due process. The records failed to show that private respondents, as the actual tillers and regular farmworkers on the land at the time of CLOA issuance, were notified or given an opportunity to be heard in the proceedings that led to the award in favor of petitioner. Due process demands that potential beneficiaries who stand to be deprived of their rights must be notified and allowed to present their claims. The DAR’s issuance of the CLOAs without such notice violated this fundamental right. Consequently, the remand to the DAR for proper hearing with due notice was correct to ascertain the rightful beneficiaries in accordance with the law’s priority scheme.