GR 131099 1999 (Digest)
G.R. No. 131099 July 20, 1999
DOMINGO CELENDRO, petitioner, vs. COURT OF APPEALS and LEONILA VDA. DE GUEVARRA, respondents.
FACTS
Leonila Vda. de Guevarra, the surviving spouse of a homestead patent awardee, owned a titled agricultural lot. In 1963, petitioner Domingo Celendro occupied and tilled a portion of the land through Guevarra’s tolerance, with the condition to vacate upon demand. After her husband’s death in 1975, Guevarra demanded Celendro’s eviction. Following unheeded demands, Guevarra filed an unlawful detainer case before the Municipal Circuit Trial Court (MCTC) of Wao, Lanao del Sur. During the pendency of this case, Celendro moved for the referral of the dispute to the Department of Agrarian Reform (DAR), but the MCTC denied the motion, ruling no landlord-tenant relationship existed and the land was titled and no longer part of a resettlement area. The MCTC ruled in Guevarra’s favor, ordering Celendro to vacate and pay rentals. This decision was affirmed by the Regional Trial Court (RTC) and became final and executory, with a writ of execution issued.
Subsequently, Celendro filed a “Petition to Quiet Title” before the DAR Adjudication Board (DARAB). The Provincial Adjudicator and, on appeal, the DARAB Central, ruled in Celendro’s favor, ordering Guevarra not to disturb his possession, effectively nullifying the final MCTC and RTC judgments. Guevarra then assailed the DARAB decision before the Court of Appeals.
ISSUE
Whether the DARAB has jurisdiction to review, reverse, or nullify a final and executory judgment rendered by a regular court.
RULING
The Supreme Court, affirming the Court of Appeals, ruled that the DARAB acted without jurisdiction and with grave abuse of discretion. The Court emphasized the fundamental doctrine of judicial hierarchy and the finality of judicial decisions. A final judgment by a court of competent jurisdiction is immutable and unalterable. The DARAB, as an administrative quasi-judicial body, possesses no appellate jurisdiction or authority to review, much less overturn, final decisions of the judiciary. Its jurisdiction is limited by statute to agrarian reform matters and does not extend to annulling final court judgments.
The Court further held that the controversy was not an agrarian dispute as there was no tenurial arrangement; Celendro was merely a tolerated occupant. Moreover, Celendro actively participated in the MCTC and RTC proceedings without questioning their jurisdiction, and he thereby acquiesced to and invoked the authority of the regular courts. A party cannot, after seeking affirmative relief from a court, later deny its jurisdiction. The DARAB’s assumption of power to set aside the final judgments of the MCTC and RTC constituted a usurpation of judicial authority, violating the principle of finality of judgments and the constitutional separation of powers. The petition was denied.
