GR 153456; (March, 2007) (Digest)
G.R. No. 153456 . March 2, 2007.
ROBERTO PADUA, Petitioner, vs. THE HON. COURT OF APPEALS, ATTY. DELFIN B. SAMSON, DEPARTMENT OF AGRARIAN REFORM, and MR. TEOFILO INOCENCIO, Respondents.
FACTS
The case involves Lot No. 90 of the Ongsiako Estate. Original tenants Pepito Dela Cruz, et al., conditionally donated the lot to the municipality in 1966. The project failed, and they later discovered the lot had been awarded to Edwin Cruz, who received a Certificate of Land Transfer (CLT). The Department of Agrarian Reform (DAR) Secretary cancelled this CLT in 1982. During the appeal to the Office of the President, Cruz waived his rights. Subsequently, DAR Secretary Miriam Defensor Santiago issued an Order in 1989 awarding the lot to Roberto Padua, who was then occupying it and paying amortizations. Dela Cruz, et al., filed a Letter-Petition for cancellation of this award.
DAR Secretary Garilao granted the petition in a 1995 Order, cancelling Padua’s award, ordering the lot’s restoration to the original tenants, and forfeiting Padua’s payments. Upon implementation of this order in 2000, Padua filed a Petition for Annulment of Judgment under Rule 47 with the Court of Appeals. He argued the DAR lacked jurisdiction as the issue involved a civil contract of sale, not an agrarian dispute, and that he was denied due process.
ISSUE
The primary issue is whether a Petition for Annulment of Judgment under Rule 47 of the Rules of Court is the proper remedy to assail a final and executory order of the DAR Secretary.
RULING
The Supreme Court denied the petition, affirming the Court of Appeals. A Petition for Annulment of Judgment under Rule 47 is available only against final judgments or orders of Regional Trial Courts or Municipal Trial Courts in the exercise of their judicial functions. It is not an available remedy to assail final orders of quasi-judicial agencies like the DAR. The proper remedy for challenging the DAR Secretary’s Order was a Petition for Review under Rule 43 of the Rules of Court, filed with the Court of Appeals within the reglementary period. Padua’s failure to avail of this correct mode of appeal rendered the DAR Order final and executory.
The Court further held that the DAR Secretary correctly exercised jurisdiction. The controversy—involving the cancellation of a CLT and the subsequent award of an agricultural land—constitutes an agrarian dispute falling squarely within the DAR’s quasi-judicial authority under the Comprehensive Agrarian Reform Law. Padua’s claim of lack of due process was unsubstantiated, as records showed he was notified of the proceedings but chose not to participate. Consequently, the DAR Order was validly issued and implemented.