G.R. No. 195412 , February 4, 2015
The Hon. Secretary of the Department of Agrarian Reform, Petitioner, vs. Nemesio Dumagpi, represented by Vicente Dumagpi, Respondent.

FACTS

On August 12, 1997, Nemesio Dumagpi filed a complaint for Accion Reivindicatoria, Quieting of Title, and Damages before the Regional Trial Court (RTC) of Pagadian City. He claimed ownership of a 211,967-square-meter land in Siay, Zamboanga del Sur, designated as Lot No. F-18-5483-D, by virtue of open, notorious, adverse, and exclusive possession since July 4, 1945. He had applied for a free patent in 1964, which was approved in 1966 but never released due to oppositions. Nemesio alleged that the private defendants (Juan Aguilar, Sr., Rosalino C. Valencia, and Dionito B. Custodio) forcibly occupied portions of his land in 1973 and 1989. He later discovered that the Department of Agrarian Reform (DAR) had issued Certificates of Land Ownership Award (CLOAs) and corresponding Original Certificates of Title (OCTs) to the private defendants over portions of the lot in 1990, and a smaller title was issued in his name without his application. The private defendants moved to dismiss the complaint, arguing the RTC lacked jurisdiction as the case involved agrarian reform implementation. The RTC denied the motion, declared the private defendants in default, and proceeded to trial. The RTC ruled in favor of Nemesio, ordering restoration of possession, cancellation of the CLOAs and OCTs issued to the private defendants, and awarding damages. The Court of Appeals affirmed the RTC decision. The Secretary of DAR then filed this petition.

ISSUE

Whether the Regional Trial Court had jurisdiction over the subject matter of the complaint, which sought the cancellation of Certificates of Land Ownership Award issued under the Comprehensive Agrarian Reform Program and the restoration of possession of the land.

RULING

The Supreme Court REVERSED and SET ASIDE the decisions of the Court of Appeals and the Regional Trial Court. It held that the RTC had no jurisdiction over the case. The subject land was part of a 2,598-hectare area proclaimed as a resettlement site under Proclamation No. 2342 (1984), to be administered and disposed of by the DAR under the Comprehensive Agrarian Reform Program. The issuance of the CLOAs and OCTs to the private defendants was an act arising from the implementation of agrarian reform laws. Under Section 2(f) of Republic Act No. 6657 (Comprehensive Agrarian Reform Law of 1988), the DAR has primary and exclusive jurisdiction, both original and appellate, to determine and adjudicate all matters involving the implementation of agrarian reform. Disputes relating to the issuance, recall, or cancellation of CLOAs fall squarely within this exclusive jurisdiction. Consequently, the RTC’s judgment was void for lack of jurisdiction. The complaint in Civil Case No. 3985 was DISMISSED.