GR 177374; (July, 2014) (Digest)
G.R. No. 177374 July 2, 2014
MARIANO JOSE, FELICISIMO JOSE, deceased, substituted by his children MARIANO JOSE, CAMILO JOSE, TIBURCIA JOSE, FERMINA JOSE, and VICTORIA JOSE, Petitioners, vs. ERNESTO M. NOVIDA, RODOLFO PALAYLAY, JR., ALEX M. BELARMINO, RODRIGO LIBED, LEONARDO L. LIBED, BERNARDO B. BELARMINO, BENJAMIN G. ACOSTA, MODESTO A. ORLANDA, WARLITO B. MEJIA, MAMERTO B. BELARMINO, MARCELO O. DELFIN and HEIRS OF LUCINO A. ESTEBAN, represented by CRESENCIA M. VDA. DE ESTEBAN, Respondents.
FACTS
In 1990, respondents were granted Emancipation Patents (EPs) and Certificates of Title as farmer-beneficiaries over portions of a 16.4142-hectare agricultural land in San Vicente, Alcala, Pangasinan, placed under Operation Land Transfer. On January 4, 1991, petitioners filed a Petition for Reinvestigation and Cancellation of Anomalously Prepared and Generated Emancipation Patents with the DAR Region I Office, claiming they were the bona fide tenant-tillers, held Certificates of Land Transfer (CLTs), and were in actual possession. They sought cancellation of respondents’ EPs and issuance of new EPs to them. On January 30, 1991, the DAR Region I Director issued an Order favoring petitioners, declaring they had a better right as beneficiaries and ordering the generation of EPs in their favor.
On December 17, 1991, respondents filed a Complaint for recovery of possession, accounting, liquidation, and damages with injunctive relief against petitioners before the DARAB Urdaneta (Case No. 01-465-EP’91). They alleged that petitioner Felicisimo Jose was the original tenant who mortgaged and abandoned the land, after which they purchased portions with DAR sanction, and that petitioners ousted them by force in 1990. Petitioners countered that they were the owner-beneficiaries and respondents never possessed the land.
On July 13, 1992, the DARAB Urdaneta ruled in favor of respondents, declaring them as tenant-beneficiaries, stating that Felicisimo Jose lost his tenancy rights by delivering possession in 1981 and going abroad, constituting abandonment.
Separately, on August 22, 1995, the DAR Secretary issued an Order affirming the DAR Region I Director’s January 30, 1991 Order favoring petitioners. However, upon respondents’ motion for reconsideration, the DAR Secretary issued another Order on June 5, 1996, noting that DARAB Case No. 01-465-EP’91 involving the same parties and cause was pending appeal, and that jurisdiction to cancel the already awarded EPs lies with the DARAB, thus remanding the case to the DARAB.
Petitioners appealed the DARAB Urdaneta Decision to the DARAB Quezon City (DARAB Case No. 1429), arguing that the DARAB Urdaneta had no jurisdiction as the case was under the exclusive jurisdiction of the DAR Secretary, and that a related case was pending before the Secretary. On June 20, 1997, the DARAB Quezon City affirmed the DARAB Urdaneta Decision in toto. The Court of Appeals affirmed the DARAB Quezon City Decision in its September 25, 2006 Decision and March 16, 2007 Resolution.
ISSUE
The core issue is whether the Department of Agrarian Reform Adjudication Board (DARAB) had jurisdiction over the complaint for recovery of possession and cancellation of Emancipation Patents, or if jurisdiction belonged exclusively to the Secretary of Agrarian Reform.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ Decision. The DARAB properly exercised jurisdiction over the case. The Court held that under the rules, the DARAB has primary and exclusive original and appellate jurisdiction over cases involving the issuance, correction, and cancellation of Emancipation Patents (EPs) which are registered with the Land Registration Authority. Since the respondents’ EPs were already registered and Certificates of Title were issued, the DARAB, not the DAR Secretary, had jurisdiction over the action for recovery of possession which inherently involved a challenge to the validity of the EPs. The Court further ruled that the factual findings of the DARAB, as affirmed by the Court of Appeals, are conclusive and binding, and there was no reason to disturb them. The DARAB correctly found that petitioner Felicisimo Jose abandoned the landholding by mortgaging and delivering possession in 1981 and subsequently going abroad, thereby terminating his tenancy relationship.