Facts:

The case revolves around a dispute between the petitioners, Spouses Buenaventura Balucan, Jr. and Yolanda Y. Balucan, along with Ruth M. Cabusas, Gemma Barcelona, and Myann Balucan, and the respondents, Spouses Lennie B. Nageli and Rudolf Nageli, represented by their attorneys-in-fact. The events transpired in Davao City, where the Department of Agrarian Reform (DAR) - Regional Office XI received a petition on January 14, 2010, from the respondents seeking the disqualification of the petitioners as Agrarian Reform Beneficiaries (ARBs) under Republic Act No. 6657, known as the Comprehensive Agrarian Reform Law of 1988. The respondents alleged that the petitioners had acquired parcels of land through fraudulent means and were not actual occupants or tillers of the said parcels. The petitioners refuted these claims, asserting their lawful status as ARBs and contending that the respondents were foreign nationals who could not legally own land in the Philippines. A series of administ

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Facts:

Background and Initiatory Pleadings

• On January 14, 2010, DAR-Regional Office XI (DAR-RO XI) received a petition filed by Spouses Lennie B. Nageli and Rudolf Nageli (collectively, Sps. Nageli) seeking:
• Disqualification of Spouses Buenaventura Balucan, Jr., Yolanda Y. Balucan, Ruth M. Cabusas, Gemma Barcelona, and Myann Balucan (collectively, Sps. Balucan et al.) as Agrarian Reform Beneficiaries (ARBs);
• Annulment of contracts;
• Cancellation of specific Transfer Certificate of Title (TCT) Nos. CL-2651, CL-2652, CL-2657, and CL-2658;
• Reconveyance of property and damages with attorney’s fees.
• In their petition, Sps. Nageli alleged that:
• In February 1994, Sps. Jose Neri Rendon and Salvacion Rendon sold two parcels of land (TCT Nos. T-211542 and T-211544) to Lennie;
• Sps. Rendon, allegedly in connivance with Sps. Balucan et al., arranged for the voluntary transfer of the land to Sps. Balucan under Republic Act No. 6657 (Comprehensive Agrarian Reform Law of 1988);
• The issuance of Certificates of Land Ownership Award (CLOAs) and subsequently the TCTs was based on this allegedly fraudulent transfer;
• Sps. Balucan et al. were not qualified to be ARBs as they were never occupants nor actively tillers of the land.

Alleged Misrepresentations and Counterclaims

• Sps. Balucan et al. denied the allegations of fraud, asserting that:
• They are the actual occupants and tillers of the subject parcels;
• Their acquisition of land title was proper and under the mandate of RA 6657;
• Sps. Nageli’s petition constituted an improper remedy owing to their status as foreigners (allegedly unable to own land) and the existence of pending cases on similar allegations, which had been previously dismissed.

Administrative Orders and Appeals

• On October 3, 2011, DAR-RO XI issued an Order disqualifying each of the petitioners from being recognized as ARBs based on:
• Their lack of permanent residency in the municipality where the land is located;
• Their failure to actively work on or till the land;
• The Order directed the Municipal Agrarian Reform Officer of Tugbok, Davao City to screen for qualified beneficiaries.
• On August 24, 2012, Sps. Balucan et al. appealed the DAR-RO XI ruling to the DAR Secretary.
• On January 26, 2020, the DAR Secretary issued an Order denying the appeal for lack of merit, thus affirming their disqualification.

Judicial Relief and Procedural Maneuvers

• On May 27, 2020, Sps. Balucan et al. filed a Petition for Certiorari before the Court of Appeals (CA), challenging both the DAR issues and their denial of appeal. They claimed:
• The proper remedy to question grave abuse of discretion was by certiorari since no plain, speedy, and adequate alternative existed;
• The DAR had acted without jurisdiction in cases regarding Sps. Nageli;
• There was inordinate delay in the resolution of their appeal;
• Sps. Nageli committed forum shopping.
• On July 21, 2021, the CA dismissed the petition, holding that:
• A Petition for Certiorari is an improper mode of appeal in this context, as the proper remedy is a Petition for Review under Rule 43;
• The petition was filed beyond the 15-day reglementary period for filing a petition for review.
• Subsequent proceedings included:
• A motion for reconsideration by Sps. Balucan et al., which was denied;
• In 2022-2023, further developments arose concerning:
• Allegations against counsel Atty. Alberto Rafael L. Aportadera for failing to provide proper copies of pleadings to Sps. Nageli’s new counsel;

ii. Sps. Nageli’s motion to dismiss the petition and seek the citation of the attorney in contempt; iii. Resolutions by the Supreme Court addressing these motions and comments, including directing Sps. Nageli to file a comment and requiring Atty. Aportadera to respond regarding the contempt issue.

Issue:

• Whether the Court of Appeals erred in dismissing Sps. Balucan et al.’s Petition for Certiorari.
• Whether the disqualification decision of Sps. Balucan et al. as Agrarian Reform Beneficiaries, rendered by DAR authorities, is void because it was issued without or in excess of jurisdiction—particularly, because the DAR allegedly failed to acquire jurisdiction over the disqualification case filed by Sps. Nageli.
• Whether Atty. Alberto Rafael L. Aportadera should be held in contempt of court for his alleged failure to send copies of pleadings to Sps. Nageli’s counsel-of-record.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)