G.R. No. 138839 . May 9, 2002.
LAURA SARNE, LORENZO JAUGAN, LOWENA ABANG-JAUGAN, PEDRO JAUGAN, and JENELYN SUSTIN-JAUGAN, petitioners, vs. HON. VIVIAN O. MAQUILING, as Provincial Adjudicator of the DAR Adjudication Board, Dumaguete City, FELISA RAFAL, ESTRELLA R. ELNASIN, CIPRIANO RAFAL, OSCAR RAFAL, and ROMANA RAFAL, respondents.

FACTS

Private respondents, claiming to be tenants, filed a complaint for redemption and damages before the DARAB against petitioners. They alleged a prior perfected contract of sale with petitioner Sarne for the tenanted portion of an agricultural lot, which Sarne subsequently sold to the other petitioners (the Jaugans). They invoked their rights of preemption and redemption under the agrarian law. Petitioners moved to dismiss, arguing lack of DARAB jurisdiction. They contended that a prior case involving the same land and parties for annulment of sale had been dismissed because the land was not under DAR or Land Bank administration, and that said dismissal was final. They further argued that the tenancy relationship had been terminated when the land was mortgaged to one of the private respondents, converting her from tenant to creditor.

ISSUE

Whether the Department of Agrarian Reform Adjudication Board (DARAB) has jurisdiction over the complaint for redemption filed by the alleged tenants.

RULING

Yes, the DARAB has jurisdiction. The Supreme Court upheld the appellate court’s ruling that the dismissal of the prior annulment case did not bar the instant redemption case. The principle of res judicata does not apply because the causes of action are different. The first case was for annulment of a contract of sale, while the present case is for the enforcement of statutory redemption rights under agrarian laws, which presupposes the existence and validity of the sale to a third party. The Court clarified that DARAB jurisdiction is not limited only to lands already under DAR or Land Bank administration and distribution. Under its rules, the DARAB has primary jurisdiction over cases involving the issuance, correction, and cancellation of Certificates of Land Ownership Award (CLOAs) and Emancipation Patents, and over cases involving the rights and obligations of persons engaged in the management, cultivation, and use of agricultural lands covered by the Comprehensive Agrarian Reform Program (CARP). The subject agricultural land, even if within a landowner’s retention limit or not yet acquired for distribution, remains under the coverage of CARP. Consequently, any controversy relating to the agrarian relationship over it, including the exercise of statutory redemption rights by a tenant, falls within the DARAB’s jurisdiction. The petition was denied.