G.R. No. 140825; October 13, 2000
CIPRIANO CENTENO, LEONILA C. CALONZO, and RAMONA ADRIANO, petitioners, vs. IGNACIA CENTENO, respondent.
FACTS
Respondent Ignacia Centeno is the owner of two parcels of riceland. In a prior case, it was established that petitioners, through fraud and misrepresentation, obtained Certificates of Land Transfer (CLTs) over these lots. The Department of Agrarian Reform (DAR) ordered the recall and cancellation of petitioners’ CLTs and directed the issuance of new CLTs in favor of respondent. This DAR order was affirmed by the Office of the President and became final and executory.
Subsequently, respondent filed a complaint with the DAR Adjudication Board (DARAB) for “Maintenance of Peaceful Possession with Prayer for Restraining Order/Preliminary Injunction, Ejectment and Damages.” She alleged that despite the final ruling awarding her the land, petitioners were interfering with her possession, harassing her, and preventing her from enjoying the fruits of the land. Petitioners, in their answer, insisted on their own possession and contested the DARAB’s jurisdiction, arguing the case was for recovery of possession cognizable by regular courts.
ISSUE
The primary issue is whether the DARAB has jurisdiction over respondent’s complaint for maintenance of peaceful possession.
RULING
The Supreme Court ruled that the DARAB has jurisdiction. The complaint is not a simple action for recovery of possession but an agrarian implementation dispute stemming from the final and executory DAR order awarding the land to respondent. Jurisdiction over agrarian disputes is vested in the DAR by Republic Act No. 6657 (Comprehensive Agrarian Reform Law). An agrarian dispute includes any controversy relating to tenurial arrangements over lands devoted to agriculture. Here, the core issue involves the enforcement of rights under the agrarian reform program, specifically the implementation of the DAR’s final order cancelling petitioners’ CLTs and awarding the land to respondent. The DARAB, as the quasi-judicial body tasked with adjudicating agrarian reform matters, has the authority to execute its final orders and resolve incidents arising from their enforcement, including complaints to maintain the awardee’s peaceful possession. The Court found petitioners’ jurisdictional challenge unmeritorious, as the case is intimately connected to the execution of a final agrarian reform adjudication.
