G.R. No. 181548 ; June 20, 2012
HEIRS OF CANDIDO DEL ROSARIO and HEIRS OF GIL DEL ROSARIO, Petitioners, vs. MONICA DEL ROSARIO, Respondent.

FACTS

The case involves a parcel of agricultural land in Bocaue, Bulacan, formerly owned by Pedro Lazaro and tenanted by spouses Jose and Florentina Del Rosario. Upon the spouses’ death, their children—Monica, Candido, and Gil—disputed the right to the land. Petitioners, heirs of Candido and Gil, claimed they continued tilling the land. They alleged that in 1991, Monica and Gil agreed that Gil would facilitate Monica’s application for an Emancipation Patent, and in exchange, Monica would cede one-third of the land to Gil. An Emancipation Patent was issued to Monica in 1998, and she obtained a Transfer Certificate of Title. When Monica refused to cede the portion, petitioners filed a complaint for amendment of title and partition before the Provincial Agrarian Reform Adjudicator (PARAD).
Monica countered that she was the sole recognized tenant-beneficiary, having taken over cultivation from her ailing father in 1950, and was the one listed with the DAR and paying amortizations. The PARAD ruled in favor of petitioners, ordering partition. The Department of Agrarian Reform Adjudication Board (DARAB) reversed the PARAD, holding that the siblings were not co-owners and that the agreement to cede land was prohibited. The Court of Appeals affirmed the DARAB.

ISSUE

Whether the PARAD and the DARAB had jurisdiction over the complaint for amendment of title and partition filed by the petitioners.

RULING

The Supreme Court reversed the Court of Appeals and declared the decisions of the PARAD and DARAB null and void for lack of jurisdiction. The Court held that jurisdiction is conferred by law and cannot be vested by the parties’ acquiescence. For the DARAB to have jurisdiction, the controversy must constitute an agrarian dispute, which presupposes a tenancy relationship between the parties. The complaint, as framed, was essentially for the enforcement of a supposed agreement for the conveyance of a portion of land and for partition based on co-ownership. The core issue was the identification of the legitimate tenant-beneficiary and the subsequent rights arising from the Emancipation Patent, not a dispute relating to agricultural tenancy over which the DARAB has expertise. The Court found no tenurial, agricultural, or economic relationship between the parties that would classify the case as an agrarian dispute. Since the DARAB lacked jurisdiction from the outset, all proceedings and decisions rendered by it, including the affirmation by the Court of Appeals, were void. The Court refrained from ruling on the substantive issues, remanding the matter for proper jurisdictional recourse.