GR 139254; (March, 2005) (Digest)
G.R. No. 139254 . March 18, 2005.
SOCIAL SECURITY SYSTEM, Petitioner, vs. DEPARTMENT OF AGRARIAN REFORM, represented by its Secretary, HONORABLE ERNESTO GARILAO, and the REGISTER OF DEEDS OF MARIKINA CITY, represented by its Registrar, GREGORIO SEMBRANO, and FARMER-BENEFICIARIES, Respondents.
FACTS
The Social Security System (SSS) owned a large parcel of land in Rodriguez, Rizal, which was placed under the coverage of the Comprehensive Agrarian Reform Program (CARP). The SSS filed for conversion of the land from agricultural to residential use before the DAR Adjudicatory Board, which was denied. This denial was affirmed with finality by the Supreme Court in a prior case (G.R. No. 122580). Subsequently, the DAR issued Certificates of Land Ownership Award (CLOAs) to identified farmer-beneficiaries, which were then registered, leading to the cancellation of the SSS’s title and the issuance of new Transfer Certificates of Title (TCTs) in the beneficiaries’ names.
The SSS filed a complaint for Annulment of Titles and Recovery of Possession before the Regional Trial Court (RTC) of San Mateo, Rizal. The SSS argued the cancellation of its Torrens title and the issuance of new TCTs were illegal, done without notice and just compensation. The respondents, including the DAR and the beneficiaries, filed a joint motion to dismiss, asserting that jurisdiction over the case properly belonged to the Department of Agrarian Reform Adjudication Board (DARAB). The RTC granted the motion and dismissed the case, prompting the SSS to elevate the matter to the Supreme Court.
ISSUE
Whether the Regional Trial Court or the Department of Agrarian Reform Adjudication Board (DARAB) has jurisdiction over the SSS’s complaint for annulment of titles and recovery of possession arising from the implementation of the CARP.
RULING
The Supreme Court ruled that the DARAB has primary and exclusive jurisdiction. The petition was denied for lack of merit. The legal logic is anchored on the nature of the dispute as intrinsically agrarian and the specific jurisdiction granted to the DARAB by law. The titles (TCTs Nos. 1259, 1260, and 1261) sought to be annulled originated directly from the CLOAs issued by the DAR pursuant to Republic Act No. 6657 (CARP Law). The SSS’s action, while framed as an annulment of titles, ultimately questioned the implementation of the CARP over its land, including the issuance and registration of the CLOAs.
The Court emphasized that under the DARAB Rules of Procedure and RA 6657, the DARAB has primary and exclusive original jurisdiction to adjudicate all agrarian disputes involving the implementation of the CARP. An “agrarian dispute” is broadly defined by law to include any controversy relating to compensation of lands acquired under the Act and the terms and conditions of transfer of ownership to agrarian reform beneficiaries. The SSS’s claim of lack of notice and just compensation falls squarely within this definition. Furthermore, by previously filing a petition for conversion with the DAR, the SSS had already invoked the agency’s jurisdiction and acknowledged the land’s agricultural character and coverage under the agrarian reform program. It cannot, after an unfavorable final ruling, assail that same jurisdiction. The RTC, therefore, correctly dismissed the case for lack of jurisdiction.