G.R. No. 186432 & 186964, March 12, 2019
The Honorable Secretary of the Department of Agrarian Reform, et al., Petitioners, vs. Heirs of Redemptor and Elisa Abucay, Respondents.

FACTS

The case originated from a 182-hectare land in Leyte purchased by the Spouses Abucay in 1983. In 1986, 22.8409 hectares of this property were placed under the Operation Land Transfer (OLT) program under Presidential Decree No. 27, and Emancipation Patents (EPs) were issued to farmer-beneficiaries, leading to the issuance of Original Certificates of Title (OCTs) in their names. The heirs of the Abucay spouses filed a complaint before the Regional Agrarian Reform Adjudicator (RARAD), arguing they received no just compensation for the covered land, as a Land Bank certificate was issued to the previous owner. The RARAD ruled in their favor, nullifying the land coverage and the issued EPs for lack of administrative due process in the valuation and notification procedures, and ordered the cancellation of the corresponding titles.
The Department of Agrarian Reform Adjudication Board (DARAB) reversed the RARAD’s decision. The DARAB held that the action filed by the Abucay heirs was essentially a protest against OLT coverage, which is classified as an agrarian law implementation (ALI) case. Under the prevailing rules, primary jurisdiction over ALI cases lies with the DAR Secretary and the Regional Director, not with the adjudicatory bodies like the RARAD or DARAB. The Court of Appeals later reinstated the RARAD’s decision, prompting the DAR officials to elevate the matter to the Supreme Court.

ISSUE

Whether the DARAB or the RARAD had jurisdiction over the complaint for the cancellation of the EPs and OCTs issued under the OLT program.

RULING

The Supreme Court ruled that the DARAB and the RARAD had no jurisdiction; jurisdiction belonged exclusively to the DAR Secretary. The Court granted the petitions and reinstated the DARAB’s decision dismissing the case for lack of jurisdiction. The legal logic is anchored on the distinction between adjudicatory and administrative-implementational functions within the DAR, and the principle of primary jurisdiction.
The complaint, although framed as one for determination and payment of just compensation and later for cancellation of titles, was in substance a protest against the coverage of the land under the agrarian reform program. Such protests are quintessential agrarian law implementation cases. Pursuant to the 2003 Rules for Agrarian Reform Implementation Cases and relevant jurisprudence, the DAR Secretary has exclusive and original jurisdiction over all matters involving the administrative implementation of agrarian laws, including protests against coverage and questions on the validity of EPs. This jurisdiction encompasses the cancellation of registered EPs and certificates of title issued under agrarian reform programs. The DARAB’s jurisdiction, in contrast, is limited to adjudicating agrarian disputes or controversies relating to tenurial arrangements. Since the core issue pertained to the correctness of the administrative act of placing the land under OLT and issuing the EPs—an implementation matter—the RARAD and the DARAB correctly should have dismissed the case for want of jurisdiction. The proper recourse for the Abucay heirs was to file their protest before the DAR Regional Director, with an appeal to the DAR Secretary. The Court emphasized that the doctrine of primary jurisdiction mandates that courts or quasi-judicial agencies like the DARAB must defer to the appropriate administrative agency on issues within its specialized competence, such as the implementation details of agrarian reform.