G.R. No. 162890 November 22, 2005
Heirs of Julian Dela Cruz and Leonora Talaro, represented by Maximino Dela Cruz, vs. Heirs of Alberto Cruz, represented by Benedicto U. Cruz.

FACTS

The Republic acquired the De Leon Estate for agrarian reform. In 1950, the DAR allocated Lot No. 778 to tenant Julian Dela Cruz, who later entered into an Agreement to Sell and received a Certificate of Land Transfer (CLT). Julian died in 1979. In 1980, his widow, Leonora, executed a private document stating she sold the rights to the lot to Alberto Cruz, with the conformity of one son, Mario. Alberto took possession, cultivated the land, and applied to purchase it. In 1990, the Provincial Agrarian Reform Officer (PARO), upon a MARO report recommending the lot be declared vacant, issued an order canceling Julian’s CLT, forfeiting previous payments, and approving Alberto’s application. A CLOA and subsequently a Transfer Certificate of Title were issued to Alberto in 1991. In 1996, the heirs of Julian, led by Maximino, discovered the transfer and filed a petition with the Provincial Agrarian Reform Adjudicator (PARAD) to nullify the PARO’s order, the CLOA, and the title, alleging lack of knowledge of the sale and violation of agrarian laws.

ISSUE

Whether the Department of Agrarian Reform Adjudication Board (DARAB) had jurisdiction over the petition for the nullification of the PARO’s order, the CLOA, and the title issued to Alberto Cruz.

RULING

No, the DARAB had no jurisdiction. The Supreme Court affirmed the Court of Appeals’ dismissal of the case but modified the ruling to be without prejudice. The core legal logic is that jurisdiction is conferred by law. The petitioners’ action essentially sought the annulment of the PARO’s administrative order and the subsequent CLOA and title. Such an action challenges the administrative acts of the DAR Secretary and his officials in the implementation of the agrarian reform program, including the award and issuance of emancipation patents and CLOAs. Under prevailing jurisprudence and DAR Administrative Order No. 6, Series of 2000, the exclusive original jurisdiction over petitions for the cancellation of CLOAs issued by the DAR Secretary lies with the DAR Secretary himself, not with the DARAB. The DARAB’s adjudicatory jurisdiction is limited to agrarian disputes or matters involving the implementation of agrarian laws, but it does not extend to reviewing or nullifying the DAR Secretary’s quasi-judicial or administrative acts in the grant of titles. Therefore, the proper remedy for the petitioners was to file a petition for cancellation directly with the Office of the DAR Secretary, following the prescribed administrative procedure, not with the PARAD/DARAB. The dismissal was without prejudice to refiling the appropriate administrative petition.