GR 157307; (February, 2006) (Digest)
G.R. No. 157307 ; February 27, 2006
AGUSTIN RIVERA, substituted by his heirs, Petitioners, vs. NEMESIO DAVID, Respondent.
FACTS
Petitioner Agustin Rivera occupied 1.8 hectares of land in Pampanga owned in common by respondent Nemesio David and other heirs. Rivera filed a complaint before the Provincial Agrarian Reform Adjudication Board (PARAB), claiming to be a tenant and seeking to maintain peaceful possession. He submitted a MARO certification and affidavits to support his claim. Respondent David countered that Rivera was a squatter who had occupied the land since 1965 without consent, operating a hollow blocks business and piggery thereon. David argued the PARAB lacked jurisdiction as the land was not agricultural and the case involved ownership.
The PARAB ruled in Rivera’s favor, finding David guilty of laches for allowing long occupation, and maintained Rivera in peaceful possession. The Department of Agrarian Reform Adjudication Board (DARAB) affirmed, adding that David’s action was barred by the statute of limitations under agrarian law. On appeal, the Court of Appeals reversed, holding the DAR had no jurisdiction because Rivera himself alleged the tenancy ended in 1957 when the land was purportedly conveyed to him as disturbance compensation.
ISSUE
Does the Department of Agrarian Reform (DAR), through the PARAB/DARAB, have jurisdiction over the complaint?
RULING
No, the DARAB had no jurisdiction. Jurisdiction over agrarian disputes is conferred by law and determined by the allegations in the complaint and the nature of the issue. Rivera’s core claim evolved from tenancy to ownership by virtue of a 1957 conveyance as disturbance compensation. The Supreme Court clarified that a tenancy relationship, essential for DARAB jurisdiction, requires consent of the parties, personal cultivation, and sharing of harvests, among other elements. Rivera’s own assertions negated a continuing tenancy; he claimed ownership since 1957. Consequently, the primary issue became one of ownership and possession, not an agrarian dispute. Such matters fall under the regular courts’ jurisdiction. The Court of Appeals correctly set aside the DARAB decision for lack of jurisdiction. The Supreme Court also noted that the DARAB’s findings on laches and the statute of limitations were made without jurisdiction and thus void. The complaint was properly dismissed, leaving the parties to pursue their claims in the proper forum.