GR 179844; (March, 2011) (Digest)
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 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, awarded them to the petitioner-farmer beneficiaries, and issued Certificates of Land Ownership Award (CLOAs), which were registered with the Register of Deeds. The respondents learned of the CLOAs only in 1998. They alleged that no notice of coverage was sent to them, no just compensation was paid, and a DAR-CENRO certification indicated the land had 24-32% slopes, making it exempt from CARP coverage. They filed complaints for reconveyance and cancellation of the CLOAs. The Provincial Agrarian Reform Adjudicator (PARAD) ruled in favor of the respondents, ordering the cancellation of the CLOAs. The Department of Agrarian Reform Adjudication Board (DARAB) reversed the PARAD, dismissing the complaints and upholding the CLOAs as valid and indefeasible. The Court of Appeals reversed the DARAB, reinstating the PARAD’s decision.
ISSUE
Whether the DARAB has jurisdiction over the respondents’ action for the cancellation of the CLOAs.
RULING
The Supreme Court REVERSED the Court of Appeals and REINSTATED the DARAB decision. The DARAB correctly dismissed the complaints for lack of jurisdiction.
The Court held that the respondents’ action for cancellation and reconveyance, based on the grounds that their properties were erroneously covered by CARP, that they were not notified, and that no compensation was paid, is essentially a protest against the CARP coverage itself. Under Section 3, Rule II of the 2003 DARAB Rules of Procedure, matters involving the administrative implementation of CARP, including the “classification and identification of landholdings for coverage” and “protests or oppositions thereto,” fall under the exclusive prerogative of the DAR Secretary, not the DARAB. The DARAB’s jurisdiction over cancellation of CLOAs is limited to cases involving the conditions for their grant or violations of agrarian laws by the beneficiaries. It does not extend to questioning the validity of the coverage decision, which is an agrarian law implementation case. Since the respondents’ core grievance challenges the administrative act of placing their land under CARP, the proper remedy was to seek recourse from the Office of the DAR Secretary, not to file an action before the DARAB. Therefore, the DARAB had no jurisdiction to entertain the complaints.