G.R. No. 163598, August 12, 2015
AGRARIAN REFORM BENEFICIARIES ASSOCIATION (ARBA), ET AL., PETITIONERS, VS. FIL-ESTATE INC., PROPERTIES, RESPONDENT. [G.R. NO. 164660] THE DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD (DARAB), AGRARIAN REFORM BENEFICIARIES, INC., ET AL., PETITIONERS, VS. KINGSVILLE CONSTRUCTION AND DEVELOPMENT CORP. AND JOHNSON ONG, RESPONDENTS. [G.R. NO. 164779] AGRARIAN REFORM BENEFICIARIES ASSOCIATION (ARBA), ET AL., PETITIONERS, VS. KINGSVILLE CONSTRUCTION AND DEVELOPMENT CORPORATION AND JOHNSON ONG RESPONDENT.

FACTS

Respondents Kingsville Construction & Development Corporation (Kingsville) and Fil-Estate Properties, Inc. (FEPI) are the owner and developer, respectively, of Forest Hills Residential Estates Phase I in Antipolo, Rizal. The subject land is a portion thereof, Lot No. “E,” covered by TCT No. 164298. In March 1996, petitioners, members of the Agrarian Reform Beneficiaries Association (ARBA), filed a complaint for maintenance of peaceful possession with prayer for preliminary injunction/TRO before the Regional Agrarian Reform Adjudicator (RARAD). They alleged they are actual occupants/farmers who entered, established residence, and cultivated the land between the 1950s and 1980s under the Green Revolution Program, and that respondents bulldozed the area on March 6, 1996. Respondents moved to dismiss, arguing the DARAB lacked jurisdiction because petitioners are squatters, not agricultural tenants, and the land is within the Lungsod Silangan Townsite reservation, outside CARP coverage per Presidential Proclamations. The RARAD initially denied the motion but a successor Regional Adjudicator granted reconsideration, dismissing the complaint for lack of jurisdiction, citing Natalia Realty Inc. v. DAR that the land was converted to residential use. On appeal, the DARAB reversed, holding the land is agricultural, petitioners are qualified beneficiaries, and the dispute is agrarian, thus within DARAB jurisdiction. It directed respondents to maintain petitioners in peaceful possession, cease development, and the MARO to place the land under CARP and issue CLOAs. Respondents’ motion for reconsideration was denied. FEPI appealed to the Court of Appeals (CA) via Rule 43. Kingsville and Ong filed a petition for certiorari before the CA, which was dismissed for being the wrong mode of appeal and filed out of time; this dismissal was affirmed by the Supreme Court and attained finality. The CA’s Sixth Division, in FEPI’s appeal, reversed the DARAB, reinstating the dismissal of petitioners’ complaint, ruling the land was reclassified as residential by Letter of Instruction No. 625 and Presidential Proclamation No. 1637 (Lungsod Silangan Townsite), and petitioners are not bona fide tenants. Petitioners’ motion for reconsideration was denied. Meanwhile, due to the finality of the ruling against Kingsville, petitioners moved for execution before the DARAB, which was granted. Respondents filed motions for reconsideration against the execution.

ISSUE

The primary issue is whether the DARAB has jurisdiction over petitioners’ complaint for maintenance of peaceful possession, which hinges on whether the subject land is agricultural land under the coverage of the Comprehensive Agrarian Reform Program (CARP).

RULING

The Supreme Court denied the petitions. It held that the DARAB did not have jurisdiction over the case. The subject land is part of the Lungsod Silangan Townsite pursuant to Presidential Proclamation No. 1637 and Letter of Instruction No. 625, which reclassified the area for residential use to absorb population overspill. Following the precedent in Natalia Realty, Inc. v. DAR, lands within this townsite reservation are excluded from CARP coverage. The Court emphasized that a townsite reservation is outside the ambit of agrarian reform. Since the land is not agricultural, the DARAB, which has jurisdiction only over agrarian disputes involving agricultural lands, acquired no jurisdiction over petitioners’ complaint. The Court also found that petitioners failed to establish a tenancy relationship, as there was no consent from the landowner and no evidence of sharing of harvests. Therefore, the CA correctly reversed the DARAB’s decision and reinstated the dismissal of the complaint for lack of jurisdiction.