GR 194554; (December, 2016) (Digest)
G.R. No. 194554 & 194556. December 07, 2016. ROMEO M. LANDICHO, et al., Petitioners, vs. WILLIAM C. LIMQUECO, Respondent.
FACTS
The petitioners are agrarian reform beneficiaries who received Certificates of Land Ownership Award (CLOAs) in 1992 for parcels of land in Lucban, Quezon, originally part of a landholding of spouses Romeo and Evangeline Landicho. The petitioners alleged that in 1994, respondent William Limqueco, in conspiracy with Romeo Landicho, obtained their signatures on documents later revealed to be contracts of sale or lease covering their awarded lands. They claimed they received no consideration, the legal implications were not explained, and their consent was vitiated by fraud. Consequently, the owner’s duplicate copies of their CLOAs and corresponding Transfer Certificates of Title (TCTs) were delivered to Limqueco.
The petitioners filed cases before the Provincial Agrarian Reform Adjudicator (PARAD) seeking the nullification of the contracts and the return of their CLOAs, arguing the transfers violated the prohibition under the Comprehensive Agrarian Reform Law (CARL) against the sale of awarded lands within ten years. Limqueco opposed, claiming he was a purchaser in good faith and that the PARAD lacked jurisdiction as no agrarian dispute existed. The PARAD and subsequently the Department of Agrarian Reform Adjudication Board (DARAB) ruled in favor of the petitioners, ordering the surrender or cancellation of the CLOAs. The Court of Appeals reversed these decisions.
ISSUE
Whether the Court of Appeals erred in reversing the DARAB decision and in ruling that the PARAD/DARAB had no jurisdiction over the petitioners’ complaint.
RULING
The Supreme Court denied the petitions and affirmed the Court of Appeals’ decision. The Court held that the PARAD and DARAB lacked jurisdiction over the case. Jurisdiction over agrarian disputes is conferred upon the DARAB under Section 50 of R.A. No. 6657 . An agrarian dispute is defined as any controversy relating to tenurial arrangements over agricultural lands, including those concerning farmworkers’ associations, represented by persons who are themselves agricultural lessees, tenants, or farmworkers.
The Court found that the controversy did not involve an agrarian dispute. The petitioners’ action was essentially for the annulment of contracts of sale/lease and the recovery of ownership and possession of land based on alleged vitiated consent and violation of the CARL’s prohibitory period. The core issue was the validity of the contracts of conveyance, which is a civil law matter. The petitioners did not claim to be tenants, lessees, or farmworkers of the respondent, nor did they assert any tenurial, leasehold, or employer-employee relationship with him. The absence of such a tenurial or agricultural relationship removed the case from the ambit of an agrarian dispute. Therefore, jurisdiction properly pertained to the regular courts, not the DARAB. The DARAB’s decision was void for lack of jurisdiction.