G.R. No. 119357 & G.R. No. 119375; July 5, 2000
Laguna Estates Development Corporation and Canlubang Sugar Estate, petitioners, vs. Honorable Court of Appeals, Department of Agrarian Reform Adjudication Board (DARAB), et al., respondents.

FACTS

The Department of Agrarian Reform placed 234.76 hectares of agricultural land in Cabuyao, Laguna under the Comprehensive Agrarian Reform Program (CARP). Certificates of Land Ownership Award (CLOAs) were subsequently issued to numerous farmer-beneficiaries, the private respondents. The awarded farmlands, however, were isolated, with the only access road being a private road network situated within the landholdings of petitioners Laguna Estates Development Corporation and Canlubang Sugar Estate. After the distribution, the petitioners prohibited the farmer-beneficiaries from using these private roads, effectively blocking ingress and egress to their newly acquired lands and impeding the delivery of CARP support services.
The farmer-beneficiaries filed a case before the DARAB, which asserted jurisdiction and issued an order granting them a right of way over the petitioners’ private road network. The petitioners separately challenged this order before the Court of Appeals, arguing that the DARAB lacked jurisdiction over the dispute. The Court of Appeals consolidated the petitions and dismissed them, upholding the DARAB’s jurisdiction. The petitioners thus elevated the case to the Supreme Court.

ISSUE

Whether the Department of Agrarian Reform Adjudication Board (DARAB) has jurisdiction to grant a right of way or easement over private property to agrarian reform beneficiaries.

RULING

The Supreme Court reversed the Court of Appeals and ruled that the DARAB has no jurisdiction over the issue. The Court clarified that for the DARAB to validly exercise jurisdiction, there must be a tenancy or agrarian relationship between the parties. Citing established jurisprudence, the Court enumerated the indispensable elements of a tenancy relationship: (1) parties are landowner and tenant; (2) subject is agricultural land; (3) there is consent; (4) purpose is agricultural production; (5) the tenant personally cultivates the land; and (6) harvest is shared.
The legal dispute in this case centered solely on the grant of a right of way—an easement—over the petitioners’ private roads. This issue did not involve any of the elements of a tenancy relationship. There was no tenurial, leasehold, or any other agrarian link between the petitioner landholders and the respondent farmer-beneficiaries concerning the road lots themselves. Consequently, the matter was not an agrarian issue but a civil one involving the use of real property. Jurisdiction over such a dispute is vested in courts of general jurisdiction under Batas Pambansa Blg. 129, not in a quasi-judicial body like the DARAB. The DARAB’s order was declared null and void, and it was permanently enjoined from conducting further proceedings in the case.