G.R. No. 183352; August 9, 2010
HEIRS OF JOSE M. CERVANTES vs. JESUS G. MIRANDA

FACTS

Arturo Miranda, holder of Certificate of Land Transfer (CLT) No. 160774 covering an agricultural lot, executed a waiver in 1981 surrendering his rights to the land in favor of his cousin, Jose M. Cervantes, due to his overseas employment and his family’s disinterest in cultivation. The Samahang Nayon approved this surrender and awarded the land to Jose. In 2002, respondent Jesus Miranda, Arturo’s brother, forcibly entered the land. Jose filed a complaint before the Provincial Agrarian Reform Adjudication Board (PARAB), submitting the waiver, resolution, tax declarations, and affidavits attesting to his tenancy. Respondent claimed he was the original tenant since the 1940s but had been abroad, becoming an American citizen, and returned in 2002 to reclaim the land, submitting an affidavit of retraction from Arturo.
The PARAB ruled for Jose, finding he had a better right as tenant and that respondent’s long absence constituted abandonment. The Department of Agrarian Reform Adjudication Board (DARAB) affirmed. The Court of Appeals reversed, holding the DARAB lacked jurisdiction as the case was essentially for forcible entry and no tenancy relationship existed between the parties, a jurisdictional requirement.

ISSUE

Whether the DARAB had jurisdiction over the dispute.

RULING

Yes, the DARAB had jurisdiction. The Supreme Court reinstated the DARAB decision. Jurisdiction is conferred by law. Under Section 50 of R.A. No. 6657, the DARAB has primary jurisdiction over agrarian disputes, which include controversies relating to tenurial arrangements over agricultural lands. The core issue here—the right to cultivate the land as a tenant-farmer under the government’s land transfer program—is quintessentially agrarian. The dispute involves the identification of the rightful tenant-beneficiary, a matter squarely within the DARAB’s expertise.
The Court of Appeals erred in characterizing the case as a simple ejectment suit. The existence of a tenancy relationship is not a prerequisite for DARAB jurisdiction; rather, it is a question to be resolved on the merits. The allegations in the complaint—concerning tenancy rights, a CLT, and an award by the Samahang Nayon—sufficiently vested jurisdiction in the DARAB. On the merits, the Supreme Court found no reason to disturb the factual findings of the PARAB and DARAB, which were supported by evidence, including the valid waiver and resolution, and which correctly held that Jose Cervantes had a superior right to the landholding.