Case Digest (G.R. No. 100091)
Facts:
Central Mindanao University represented by its President Dr. Leonardo A. Chua v. The Department of Agrarian Reform Adjudication Board, the Court of Appeals and Alvin Obrique, representing Bukidnon Free Farmers Agricultural Laborers Organization (BUFFALO), G.R. No. 100091, October 22, 1992, Supreme Court En Banc, Campos, Jr., J., writing for the Court.The petition arose from a complaint filed with the Department of Agrarian Reform Adjudication Board (DARAB) by members of the group calling itself Bukidnon Free Farmers and Agricultural Laborers Organization (BUFFALO) under the leadership of Alvin Obrique and others, seeking a Declaration of Status as Tenants and coverage of portions of the Central Mindanao University (CMU) land under the Comprehensive Agrarian Reform Program (CARP). The DARAB issued a decision on September 4, 1989 finding the complainants were not tenants but nonetheless ordered the segregation of 400 hectares of the CMU reservation for inclusion in CARP; the Court of Appeals affirmed that decision on August 20, 1990. The CMU filed a petition for review on certiorari under Rule 65 to the Supreme Court contesting DARAB’s jurisdiction and the Court of Appeals’ affirmation.
The lands in dispute form part of a 3,080-hectare reservation granted to what became the CMU by Proclamation No. 476 (January 16, 1958) and were surveyed and titled under original certificates of title. Historically the CMU, as a land‑grant agricultural school, used its reservation for research, experimental stations, watershed, crop projects and other educational purposes. To augment resources and provide training, CMU implemented livelihood/self‑help programs (the 1984 “Kilusang Sariling Sikap Program” and the later CMU‑Income Enhancement Program) that permitted groups of faculty, staff and later some former employees to cultivate specified plots under written agreements that expressly disclaimed a landlord‑tenant relationship and imposed conditions (nominal fees, prohibition on residence in project area, prohibition on using plots as collateral).
Some participants (including Obrique, a former CMU instructor and former assistant director of an agri‑business project) were later separated from CMU service and certain contracts were not renewed; notices to vacate followed. Thereupon the complainants filed the agrarian case. In its adjudication the DARAB found the complainants were not tenants nor shown to be landless peasants, yet proceeded to order segregation of 400 hectares on the ground that portions of the reservation had been leased or managed by third parties (e.g., Philippine Packing Corporation/Del Monte) and therefore the land was not “actually, directly and exclusively” used for school purp...(Pro-only)
Issues:
- Did the DARAB have jurisdiction to hear and decide Case No. 005 for Declaration of Status of Tenants and to order segregation of 400 hectares of the CMU land under the CARP?
- Did the Court of Appeals commit serious errors and grave abuse of discretion in dismissing CMU’s petition for review and affirm...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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