G.R. No. 261059 . February 15, 2023.
ADRIANO S. LORENZO, SR., JOSE D. FLORES III, REPRESENTED BY HIS FATHER, JOSE R. FLORES, JR., AND CARLOS S. FLORES, PETITIONERS, VS. DOMINADOR M. LIBUNAO, EVAGRIO S. LIBUNAO, NOE S. LIBUNAO, MAYO S. LIBUNAO, AND DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD (DARAB), RESPONDENTS.

FACTS

Petitioners Adriano S. Lorenzo, Sr., Jose D. Flores III, and Carlos S. Flores filed an Amended Complaint for Cancellation of Titles and Emancipation Patents and Maintenance of Possession before the Provincial Agrarian Reform Adjudicator (PARAD) against respondents Dominador M. Libunao, Evagrio S. Libunao, Noe S. Libunao, and Mayo S. Libunao. The case involved a nine-hectare portion of agricultural land in Barangay San Roque, La Paz, Tarlac. Petitioners alleged they and their predecessors-in-interest had been in possession of the land since 1978 and had filed applications to be declared qualified farmer-beneficiaries, but their applications were reported missing. They discovered in 2003 that emancipation patents and titles over the land had been issued to respondents, which they believed was obtained through fraudulent means as respondents never possessed or cultivated the land. Respondents denied fraud, asserting they were duly identified by the Municipal Agrarian Reform Office (MARO) and the Department of Agrarian Reform (DAR) as qualified farmer-beneficiaries and had been in actual possession of their respective landholdings. The PARAD dismissed the complaint, upholding the validity of respondents’ emancipation patents and titles, a decision affirmed by the DARAB. The DARAB later denied petitioners’ Motion for Reconsideration, stating it lacked jurisdiction as the exclusive original jurisdiction over cancellation cases had been transferred to the DAR Secretary under Republic Act No. 9700 . The Court of Appeals affirmed the DARAB’s ruling, prompting petitioners to elevate the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

The core issue is whether the Court of Appeals, PARAD, and DARAB erred in not appreciating petitioners’ evidence and in upholding the emancipation patents and titles issued to respondents, and who between the parties are qualified beneficiaries entitled to the land.

RULING

The Supreme Court denied the petition, affirming the Court of Appeals’ Decision and Resolution. The Court held that the CA correctly ruled that the DARAB lacked jurisdiction to resolve petitioners’ appeal upon the enactment of Republic Act No. 9700 , which transferred exclusive and original jurisdiction over all cases involving the cancellation of emancipation patents, certificates of land ownership award, and other titles issued under any agrarian reform program to the Secretary of the DAR. This transfer was effective from the law’s approval on August 7, 2009, and petitioners filed their appeal with the DARAB on November 20, 2009, at which point the DARAB no longer had jurisdiction. Furthermore, the Court emphasized that a petition for review under Rule 45 is limited to questions of law, not fact, and petitioners were essentially asking for a re-evaluation of evidence, which is outside the Court’s scope. The doctrine of primary jurisdiction also applies, requiring that relief must first be sought from the administrative body (the DAR Secretary) possessing the requisite expertise before resorting to the courts. Thus, the petition was found to be without merit.