Case Digest (G.R. No. 163598)
Facts:
Agrarian Reform Beneficiaries Association (ARBA) v. Fil‑Estate Properties, Inc., et al., G.R. Nos. 163598, 164660 and 164779, August 12, 2015, Supreme Court Third Division, Jardeleza, J., writing for the Court.Members of ARBA (petitioners) filed a complaint in March 1996 with the Regional Adjudicator (RARAD) of the Department of Agrarian Reform Adjudication Board (DARAB) Region IV for maintenance of peaceful possession against Fil‑Estate Properties, Inc. (FEPI), Kingsville Construction & Development Corporation (Kingsville) and Johnson Ong (respondents), alleging long occupation and cultivation of a parcel within Forest Hills Residential Estates Phase I in Antipolo, Rizal (Lot E, TCT No. 164298), and seeking injunctive relief after bulldozing and leveling activities. Respondents moved to dismiss for lack of DARAB jurisdiction, arguing petitioners were mere squatters, the land was titled and reclassified as the Lungsod Silangan townsite (excluded from CARP), and no tenancy was alleged.
The first Regional Adjudicator denied the motion to dismiss (September 11, 1997), but a succeeding RARAD reversed and dismissed on September 8, 1998, holding the land excluded from CARP under Presidential Proclamation No. 1637. Petitioners appealed to the DARAB, which on January 11, 2001 reversed the RARAD: DARAB found the land agricultural (MARO certification), declared petitioners qualified beneficiaries under Section 22 of R.A. No. 6657 (CARP), ordered respondents to maintain petitioners in peaceful possession, to cease development, and directed MARO to place the land under CARP and issue CLOAs; DARAB denied reconsideration (April 23, 2002).
Respondents pursued relief in the Court of Appeals (CA) by separate petitions. FEPI appealed under Rule 43 (CA G.R. No. 70717, filed May 31, 2002). Kingsville and Ong filed a certiorari petition treated as Rule 65 (CA G.R. No. 71055, filed June 2, 2002), which the CA Special Seventh Division dismissed as the wrong remedy and for defective verification. The CA Sixth Division later (October 22, 2003) reversed DARAB in CA G.R. No. 70717, holding the land had been reclassified as residential under Presidential Proclamation No. 1637 and related zoning approvals, and that petitioners had not established a tenancy relationship; petitioners’ motion for reconsideration was denied (May 6, 2004).
Despite the CA rulings, DARAB issued a writ of execution (February 17, 2004) to implement its January 11, 2001 decision, prompting FEPI to obtain from the CA a 60‑day TRO (enjoining DARAB’s enforcement) and later the CA’s view that, with denial of petitioners’ motion for reconsideration, adjudication on a writ of preliminary injunction became unnecessary. Kingsville then filed a certiorari petition (CA G.R. SP No. 82322, filed March 14, 2004), which the CA granted (June 10, 2004) on the ground that DARAB lacked jurisdiction because the land had been converted/reclassified to non‑agricultural use and petitioner...(Pro-only)
Issues:
- Does the DARAB have jurisdiction over the dispute between the parties?
- Did a tenancy relationship exist between petitioners and respondents?
- Is a conversion order from DAR necessary despite prior executive or local acts excluding the land from CARP?
- Was the TRO issued by the Court of Appeals in CA G.R. No. 70717 improper?
- Does the dismissal of CA G.R. No. 71055 operate as res judicata to bar later petitions?
- Were respondents guilty of forum‑shopping in filing multiple petitions in the Court of Appeals?
- Was the Court of Appeals Sixth Division obliged to dismiss CA G.R. No. 70717 upon notice of the pendency or dismissal of CA G.R. No. 71055?
- May FEPI and Kingsville...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)