G.R. No. 200369 & G.R. Nos. 203330-31, March 1, 2017
Union Bank of the Philippines, Petitioner, vs. Various Agrarian Reform Officers and Numerous Named Individuals, Respondents.

FACTS

Petitioner Union Bank of the Philippines, the registered owner of two parcels of land in Calamba, Laguna, voluntarily offered these lands for sale to the government under the Comprehensive Agrarian Reform Program (CARP). Disagreeing with the valuation set by the Land Bank, the Department of Agrarian Reform (DAR) opened trust accounts and proceeded to issue Certificates of Land Ownership Award (CLOAs) to numerous farmer-beneficiaries. Union Bank subsequently sought to withdraw its voluntary offer and secure an exemption from CARP coverage, arguing the lands were undeveloped and had a slope exceeding 18%. The DAR Secretary denied this request.
Union Bank then filed a petition before the DAR Adjudication Board (DARAB) seeking the cancellation of the issued CLOAs. The DARAB dismissed the petition for lack of jurisdiction, a ruling affirmed by the Court of Appeals. The CA held that the DARAB’s jurisdiction is limited to agrarian disputes, which require a tenurial relationship between the parties. Since the dispute was between the landowner and the DAR regarding the propriety of CARP coverage, no such tenurial relationship existed.

ISSUE

The primary issue is whether the DARAB has jurisdiction over a petition for the cancellation of CLOAs filed by a landowner against agrarian reform beneficiaries where no tenancy relationship exists between them.

RULING

No, the DARAB has no jurisdiction. The Supreme Court affirmed the rulings of the DARAB and the Court of Appeals. Jurisdiction over agrarian disputes is conferred by law. Under Section 50 of the Comprehensive Agrarian Reform Law, the DAR is vested with quasi-judicial powers, but the DARAB’s jurisdiction, as defined by its own rules, is explicitly limited to “agrarian disputes,” which by legal definition under Section 3(d) of the same law involve relationships between agricultural workers/tenants and landowners. The core of Union Bank’s petition was a challenge to the DAR’s administrative decision to place the land under CARP and issue CLOAs, which is a matter of CARP implementation falling under the DAR’s primary jurisdiction, not the DARAB’s adjudicatory function. Since the controversy was between the landowner and the DAR (through the beneficiaries), and not an agrarian dispute arising from a tenurial link, the DARAB correctly declined jurisdiction. The proper remedy for the landowner was to appeal the DAR Secretary’s administrative order denying exemption through a judicial review via a Rule 43 petition with the Court of Appeals.