Title
Concha vs. Rubio
Case
G.R. No. 162446
Decision Date
Mar 29, 2010
A dispute arises over the selection of qualified farmer-beneficiaries for a portion of land under the Comprehensive Agrarian Reform Program, leading to a legal battle between petitioners and respondents, ultimately resolved by the Supreme Court in favor of the petitioners.
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Case Digest (G.R. No. 162446)

Facts:

  • The case Concha v. Rubio (G.R. No. 162446) centers on the selection of farmer-beneficiaries under the Comprehensive Agrarian Reform Program (CARP).
  • Romanita Concha and other petitioners contested the identification of beneficiaries for approximately 33.5006 hectares of land covered by Transfer Certificate of Title Nos. T-140494, T-140492, and T-140491.
  • A Notice of Coverage was issued on June 16, 1993, indicating the land's inclusion in CARP's Compulsory Acquisition Scheme.
  • On August 17, 1993, the Municipal Agrarian Reform Officer (MARO) identified several beneficiaries, including some petitioners.
  • Respondents, including Paulino Rubio, filed a complaint on March 24, 1995, claiming tenancy rights and seeking recognition as beneficiaries.
  • The landowners requested conversion for development, which the Department of Agrarian Reform (DAR) approved on April 26, 1995, designating remaining land to qualified farmer-beneficiaries.
  • Petitioners received Certificates of Land Ownership Awards (CLOAs), while respondents were compensated for disturbance.
  • Respondents' case to annul the CLOAs was initially dismissed by the Provincial Adjudicator (PARAD) for lack of merit.
  • The DARAB later ruled in favor of the respondents, prompting several appeals, with the Court of Appeals initially siding with petitioners but later reinstating DARAB's decision.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the petitioners, reversing the Amended Decision of the Court of Appeals.
  • The Court reinstated the earlier decision of the Court of Appeals, affirming the titles over the subject land issued to the petitioners.
  • The Court concluded that DARAB did not have jurisdiction over the ide...(Unlock)

Ratio:

  • The Supreme Court underscored that the identification and selection of CARP beneficiaries are administrative functions solely within the jurisdiction of the Secretary of the Department of Agrarian Reform.
  • The Court asserted that such matters should not be adj...continue reading

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