GR 214714; (October, 2020) (Digest)
G.R. No. 214714. October 07, 2020
PHILCONTRUST RESOURCES, INC. (FORMERLY KNOWN AS INTER-ASIA LAND DEVELOPMENT CO.), PETITIONER, VS. ATTY. REYNALDO AQUINO, IN HIS CAPACITY AS THE REGISTER OF DEEDS OF TAGAYTAY CITY, AND MR. DANILO ORBASE, IN HIS CAPACITY AS THE PROVINCIAL AGRARIAN REFORM OFFICER OF TRECE MARTIRES, CAVITE, JESUS D. EBDANI, ET AL., RESPONDENTS.
FACTS
Petitioner Philcontrust Resources, Inc. is the registered owner of several parcels of land in Tagaytay City. The Provincial Agrarian Reform Office (PARO) of Cavite informed petitioner that the lands were covered by the Comprehensive Agrarian Reform Program (CARP). Consequently, Certificates of Land Ownership Award (CLOAs) were issued to farmer-beneficiaries, and the Register of Deeds cancelled petitioner’s titles, issuing new ones in the name of the Republic of the Philippines. Aggrieved, petitioner filed a Petition for Cancellation of the CLOAs before the Provincial Agrarian Reform Adjudicator, arguing the lands were residential and non-agricultural, thus exempt from CARP. It presented certifications from various agencies, including the HLURB and the City Planning Office, to support this claim.
The Regional Adjudicator dismissed the petition, ruling that the certifications were insufficient for cancellation and could only serve as grounds for an application for exemption with the DAR Secretary. The DARAB affirmed this dismissal. Petitioner elevated the case to the Court of Appeals, which also affirmed the DARAB’s decision. Hence, this petition.
ISSUE
Whether the DARAB and the Court of Appeals erred in dismissing the petition for cancellation of CLOAs on the ground that the determination of land classification and exemption from CARP coverage is within the exclusive jurisdiction of the DAR Secretary, not the DARAB.
RULING
The Supreme Court denied the petition and affirmed the assailed decisions. The legal logic is grounded in the distinct jurisdictions of the DAR Secretary and the DARAB under the law. The DARAB is a quasi-judicial body with jurisdiction over agrarian disputes, such as those involving tenurial arrangements. Conversely, the DAR Secretary, as the chief executive officer of the Department, possesses primary and exclusive jurisdiction over matters involving the administrative implementation of agrarian reform. This includes the classification and identification of landholdings for coverage and applications for exemption.
The petitioner’s core challenge—that the lands are non-agricultural and thus exempt—is fundamentally a question of land classification for CARP coverage. This is explicitly within the DAR Secretary’s jurisdiction under the DARAB Rules of Procedure and settled jurisprudence. The Court emphasized that a petition for cancellation of a CLOA based on exemption must be preceded by a positive act from the DAR Secretary declaring the land exempt. The various certifications presented by the petitioner, while relevant, do not constitute such a declaration. Therefore, the DARAB correctly declined to rule on the exemption claim, as doing so would have been an encroachment on the executive function of the DAR Secretary. The proper recourse for the petitioner was to first seek a formal exemption or clearance from the DAR Secretary.