G.R. No. 229891 - Abella vs. Villan

Eutiquiano T. Armario was the original farmer-beneficiary awarded four farmlots with an aggregate area of 3.4289 hectares.
Municipal Agrarian Reform Officer (MARO) Victor N. Honrado initially informed the Provincial Agrarian Reform Officer that the allotted farmlots had an excess area of 0.4289 hectares, recommending segregation and transfer of this excess.
On June 29, 1990, a revised recommendation by Municipal AGR Officer Jose M. Segovia adjusted the excess area to 0.9712 hectares, which was subsequently recorded on Abella’s Emancipation Patent Form No. 2.
The adjusted Emancipation Patent No. 147186 was transmitted and later released to Reynaldo Abella, with Transfer Certificate of Title (TCT) No. EP-219 eventually issued in his name based on Presidential Decree No. 27.

Despite the issuance of the Emancipation Patent and TCT, Eutiquiano continued to permit his daughter, Maria Armario Villan, to physically occupy a portion of the lot covered by TCT No. EP-219.
On September 8, 1997, a joint affidavit of ownership executed by Eutiquiano and Reynaldo Abella confirmed the agreement to bequeath the lot portion (where Villan’s house was constructed) to Maria Armario Villan.
Following Eutiquiano’s death on November 7, 1997, his heirs executed an extrajudicial settlement awarding a portion of his lot to Villan, with the area “to be deducted from the share of Adalia Abella.”
On January 26, 2000, Abella confirmed through an affidavit that he was transferring 3,831 square meters of his lot to Villan.
On June 19, 2000, the City Agrarian Reform Officer of Legazpi City issued a certification recognizing Villan’s right over the 3,831 square meters, identifying the portion as Lot No. 1713-B-2-A.

Villan first filed a complaint for cancellation of TCT No. EP-219 with the Regional Trial Court of Legazpi; the complaint was dismissed without prejudice due to lack of jurisdiction.
Upon dismissal, Villan filed a petition for restoration and/or correction of entries in TCT No. EP-219 against Spouses Reynaldo and Adalia Abella before the Department of Agrarian Reform.
The Regional Agrarian Reform Adjudicator, relying on documents including Ministry Memo Circular No. 4, Series of 1986, ruled in favor of Villan by finding that Eutiquiano did not consent to the reallocation of his excess land to Abella, and directed the transfer of 3,831 square meters to her.
The Abella Spouses filed a motion for reconsideration, which was denied, and subsequently appealed the decision to the Department of Agrarian Reform Adjudication Board (DARAB), which affirmed the lower adjudicator’s ruling.
The Court of Appeals later dismissed Adalia’s appeal and upheld the DARAB decision, confirming the Board’s jurisdiction over disputes involving the implementation of the Comprehensive Agrarian Reform Program (CARP).
Adalia then elevated the matter to the Supreme Court through a Petition for Review on Certiorari, challenging both the jurisdiction of the DARAB and the reallocation decision.

Petitioner (Adalia Armario Abella), as the surviving spouse of Reynaldo Abella, contended that her husband was the rightful beneficiary of the entire lot as evidenced by TCT No. EP-219, asserting:

Her father had no objection to the transfer as the title was issued after he personally delivered the land title to Abella.
Her husband diligently paid the monthly amortizations and that the property was acquired from conjugal funds, thereby constituting community property.

The series of joint affidavits, the extrajudicial settlement executed by Eutiquiano’s heirs, and Abella’s own affidavit evidenced that Eutiquiano’s true intent was to bequeath a portion of the land (3,831 sq.m.) to her.
The reallocation properly reflected Eutiquiano’s wish and was acknowledged by the entire family, including the Abella Spouses.

Petitioner also raised procedural issues regarding the alleged lack of summons to the Department of Agrarian Reform Provincial Office, questioning the jurisdiction of the DARAB.
In her comment, respondent highlighted that petitioner raised questions of fact (which are not proper under a Rule 45 petition) and that the Petitioner’s petition was filed out of time.

The Regional Agrarian Reform Adjudicator’s decision, which directed the transfer of the land portion in favor of Villan, was confirmed after motions for reconsideration were denied.
The Department of Agrarian Reform Adjudication Board and subsequently the Court of Appeals affirmed the ruling, emphasizing that the controversy was within the scope of agrarian reform matters.
The Supreme Court was then called upon to review the case, focusing on issues of jurisdiction and the proper reallocation of land under agrarian laws.

Whether the DARAB had the requisite jurisdiction to hear and decide the petition for restoration and/or correction of entries in TCT No. EP-219, given that the matter involved the implementation of the Comprehensive Agrarian Reform Program.
Whether the alleged failure to issue summons on the Department of Agrarian Reform Provincial Office affected the Board’s jurisdiction over the case.

Whether the reallocation and transfer of 3,831 square meters from the lot originally issued under TCT No. EP-219 in favor of Reynaldo Abella to Maria Armario Villan was proper and in accordance with the original intent of the original farmer-beneficiary, Eutiquiano.
Whether the evidentiary basis—including joint affidavits, extrajudicial settlements, and subsequent affidavits—sufficiently supported the respondent’s claim against the assertions made by the petitioner.