GR 163285; (February, 2008) (Digest)
G.R. No. 163285 ; February 27, 2008
DEPARTMENT OF AGRARIAN REFORM, rep. by REGIONAL DIRECTOR NASER M. MUSALI, petitioner, vs. HON. HAKIM S. ABDULWAHID, Presiding Judge, Regional Trial Court, Br. XII of Zamboanga City, and YUPANGCO COTTON MILLS, INC., respondents.
FACTS
Yupangco Cotton Mills, Inc. (Yupangco) filed a complaint before the Regional Trial Court (RTC) of Zamboanga City against the Department of Agrarian Reform (DAR), the Land Bank of the Philippines, and the Buenavista Yupangco Agrarian Reform Beneficiaries Association, Inc. (BYARBAI). The complaint, denominated as one for “Recovery of Ownership and Possession, Violations of R.A. Nos. 6657 and 3844, Cancellation of Title, Reconveyance and Damages,” alleged that DAR had erroneously placed Yupangco’s land under the Comprehensive Agrarian Reform Program (CARP) and issued Certificates of Land Ownership Award (CLOAs) to BYARBAI without prior payment of just compensation. Yupangco sought to recover the land and cancel the issued titles.
The DAR filed a Motion to Dismiss, asserting that the RTC lacked jurisdiction as the case involved an agrarian reform matter falling under the primary and exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB). The RTC denied the motion, ruling it had jurisdiction as the action was essentially for recovery of ownership. The Court of Appeals sustained the RTC, prompting the DAR to elevate the case to the Supreme Court via a petition for review on certiorari.
ISSUE
Whether the Regional Trial Court or the Department of Agrarian Reform Adjudication Board (DARAB) has jurisdiction over Yupangco’s complaint.
RULING
The Supreme Court granted the petition and ruled that jurisdiction lies with the DARAB. The Court emphasized that jurisdiction is determined by the allegations in the complaint and the nature of the issue subject of the controversy, not merely by the prayer or title of the pleading. While Yupangco’s complaint was framed as an action for recovery of ownership, a scrutiny of its material allegations revealed that the core issue was the propriety of the CARP coverage, the distribution of the land to agrarian reform beneficiaries, and the cancellation of the issued CLOAs.
These matters are intrinsically linked to the implementation of the agrarian reform program. Under Section 50 of Republic Act No. 6657 (CARP Law), the DAR is vested with primary jurisdiction over all agrarian reform matters, and the DARAB has exclusive original jurisdiction over cases involving the issuance, correction, and cancellation of CLOAs. Since the controversy is an incident involving CARP implementation and qualifies as an “agrarian dispute” concerning the terms of transfer of ownership from landowner to beneficiaries, it falls squarely within the DARAB’s specialized competence. Consequently, the RTC committed grave abuse of discretion in taking cognizance of the case. The Supreme Court reversed the assailed CA Decision and Resolution and ordered the dismissal of Civil Case No. 5113.