G.R. No. 179844; March 23, 2011
Emerson B. Bagongahasa, et al., Petitioners, vs. Johanna L. Romualdez, Respondent. (Consolidated Cases)

FACTS

The respondents (Johanna L. Romualdez, Dietmar L. Romualdez, Spouses Daniel and Ana Romualdez, and Jacqueline L. Romualdez) are the absolute owners of three separate parcels of land in Sitio Papatahan, Paete, Laguna, purchased in 1994 and 1998. The properties are planted with fruit-bearing trees, and they and their predecessors-in-interest have been in possession for over thirty years and have paid realty taxes. In 1994 and 1995, the Secretary of Agrarian Reform declared the properties part of the public domain under Presidential Proclamation No. 2282 (1983) and awarded them to the petitioner-farmers, issuing Certificates of Land Ownership Award (CLOAs) which were registered with the Register of Deeds of Siniloan, Laguna. The respondents learned of the CLOAs only in 1998. They filed complaints for reconveyance and cancellation of the CLOAs, alleging that: (1) their lands were private properties, not public domain; (2) no notice of CARP coverage was sent to them; (3) no just compensation was paid; and (4) a DAR-CENRO certification indicated the lands had 24-32% slopes, making them exempt from CARP. The petitioners, the farmer-beneficiaries and DAR officials, argued that the lands were part of the alienable public domain distributed under the CARP, the CLOAs were regularly issued, and their registration made the titles indefeasible.
The Provincial Agrarian Reform Adjudicator (PARAD) ruled in favor of the respondents, ordering the cancellation of the CLOAs due to mistake in CARP coverage and lack of due process (no notice, no compensation). The DARAB reversed the PARAD, dismissing the complaints. It held that the complaints were virtual protests against CARP coverage, over which it had no jurisdiction, as such matters are vested in the DAR Secretary. It also ruled that the registered CLOAs had become incontestable. The Court of Appeals reversed the DARAB, reinstating the PARAD decision, holding that the DARAB had jurisdiction to cancel the registered CLOAs and that the respondents were deprived of due process.

ISSUE

Whether the Court of Appeals erred in ruling that the DARAB has jurisdiction to cancel the CLOAs issued to the petitioner-farmers and in ordering their cancellation.

RULING

The Supreme Court GRANTED the petitions, REVERSED and SET ASIDE the Court of Appeals Decision and Amended Decision, and REINSTATED the DARAB Decision dismissing the complaints.
The Court held that the DARAB correctly dismissed the complaints for lack of jurisdiction. The core issue raised by the respondents—that their privately owned lands were erroneously included in the CARP coverage—is a matter of agrarian law implementation, specifically involving the “classification and identification of landholdings for coverage.” Under Section 3, Rule II of the 2003 DARAB Rules of Procedure, such matters are under the exclusive prerogative and cognizance of the DAR Secretary, not the DARAB. The DARAB’s jurisdiction over cancellation of registered CLOAs is not absolute; it cannot be exercised to review or overturn the DAR Secretary’s administrative determination on land classification and coverage. Since the respondents’ action was essentially a protest against the initial coverage and issuance of the CLOAs, jurisdiction properly pertained to the Office of the DAR Secretary.
Furthermore, the Court clarified that the registration of the CLOAs did not automatically render them indefeasible or beyond challenge. The principle of indefeasibility of a Torrens title does not apply to titles secured by fraud or misrepresentation. However, in this case, the proper remedy for the respondents was not an action for cancellation before the DARAB, but an appeal to the Office of the President or a direct judicial action to question the DAR’s administrative determination, which they did not timely pursue. Consequently, the DARAB did not have the authority to cancel the CLOAs based on the grounds raised by the respondents.