GR 149553; (February, 2008) (Digest)
G.R. No. 149553 ; February 29, 2008
NICOLAS LAYNESA and SANTOS LAYNESA, petitioners, vs. PAQUITO and PACITA UY, respondents.
FACTS
Petitioners Nicolas and Santos Laynesa were tenants on a four-hectare agricultural land originally owned by Robert Morley, later sold to Sixto Cuba, Sr. In 1993, Sixto Cuba, Jr. executed a Deed of Absolute Sale over the entire property in favor of respondent Pacita Uy. The Laynesas, as tenants, filed a petition for legal redemption before the Department of Agrarian Reform Adjudication Board (DARAB). Subsequently, the heirs of Cuba, Sr. filed a civil case to annul the sale. The civil case was settled via a Compromise Agreement, resulting in the subdivision of the property and the issuance of Transfer Certificate of Title No. 23276 for a two-hectare portion in the names of the spouses Uy. The Municipal Council later reclassified this land from agricultural to industrial.
The Laynesas then filed a new DARAB case seeking to redeem the two-hectare portion now titled under the Uys. The DARAB granted the redemption. The Court of Appeals reversed, holding that DARAB lost jurisdiction because the land had been administratively reclassified to industrial before the filing of the redemption case.
ISSUE
Whether the DARAB retained jurisdiction over the Laynesas’ action for legal redemption despite the local government’s reclassification of the land from agricultural to industrial.
RULING
Yes, the DARAB retained jurisdiction. The Supreme Court reversed the Court of Appeals and reinstated the DARAB’s decision, with modification. The Court held that jurisdiction is determined by the allegations in the complaint and the law at the time of its filing. The Laynesas’ complaint was an agrarian action for legal redemption, a right granted to agricultural tenants under agrarian laws, which falls under the DARAB’s exclusive original jurisdiction.
Crucially, the purported reclassification was legally ineffectual. For a valid reclassification, the Department of Agrarian Reform (DAR) must first approve the conversion of the land from agricultural to non-agricultural use, pursuant to its mandate under the Comprehensive Agrarian Reform Law. The mere enactment of a municipal zoning ordinance, without prior DAR clearance, does not effectively remove the land from agrarian reform coverage or strip the DARAB of jurisdiction. Since the land was agricultural at the time the tenancy relationship was established and the cause of action for redemption accrued, the DARAB properly exercised jurisdiction. The Court, however, deleted the award of damages for lack of basis.