GR 190482; (December, 2015) (Digest)
G.R. No. 190482 December 9, 2015
DEPARTMENT OF AGRARIAN REFORM, represented by MS. FRITZI C. PANTOJA, Petitioner vs. IGMIDIO D. ROBLES, et al., Respondents
FACTS
Eduardo Reyes was the registered owner of agricultural lands in Laguna. On April 17, 1997, he sold these subdivided lots to the respondents, Igmidio D. Robles and others. The deeds of absolute sale were registered on May 3, 2005, and new Transfer Certificates of Title (TCTs) were issued in the respondents’ names. Subsequently, on May 26, 2006, the Department of Agrarian Reform (DAR), through its Provincial Agrarian Reform Officer, filed a Petition for Annulment of Deeds of Absolute Sale and Cancellation of the TCTs before the Provincial Agrarian Reform Adjudicator (PARAD). The DAR alleged the sales were void for being executed without prior DAR clearance, violating Section 6 of Republic Act No. 6657 (Comprehensive Agrarian Reform Law).
The respondents, along with other parties, moved to dismiss the petition, arguing the DAR Adjudication Board (DARAB) lacked jurisdiction. The Provincial Adjudicator denied the motion to dismiss against the respondents. On appeal, the Court of Appeals reversed the PARAD’s resolutions and dismissed the DAR’s petition for lack of jurisdiction.
ISSUE
Whether the DARAB, through its adjudicators, has jurisdiction over the DAR’s petition for annulment of the deeds of sale and cancellation of the titles issued to the respondents.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision, holding that the DARAB had no jurisdiction. The Court’s legal logic centered on the nature of the action and the status of the land. Jurisdiction over agrarian disputes is conferred by law. For the DARAB to have jurisdiction under its rules, the case must involve the “sale, alienation, pre-emption, and redemption of agricultural lands under the coverage of the CARL.”
The Court found the subject lands were not under CARP coverage at the time of the contested sale in 1997. The DAR’s own petition admitted that a Notice of Coverage was issued only later and, critically, it was issued to the heirs of the original owner and not to the current registered owners, the respondents. Since the sale to the respondents was completed and titles were issued before any valid coverage, the land was not yet “under the coverage of the CARL” when the alienating act occurred. Consequently, the action was not an agrarian dispute but a simple action for annulment of sale and cancellation of title, which falls under the jurisdiction of the regular courts. The DAR’s belated issuance of a notice to the wrong parties did not retroactively confer DARAB jurisdiction over a concluded transaction.