AC-1928 - IN RE: Edillion

The land in dispute covers an aggregate area of 33.5006 hectares, identified by Transfer Certificate of Title Nos. T-140494, T-140492, and T-140491, registered in the names of Lilia E. Gala, Luisita E. Gala, and Teresita E. Gala, respectively.
The landholding was placed under the Compulsory Acquisition Scheme of the Comprehensive Agrarian Reform Program (CARP).
A Notice of Coverage was issued to the landowners on June 16, 1993.

The Municipal Agrarian Reform Officer (MARO) of Tiaong, Quezon, in her affidavit dated August 17, 1993, identified an initial list of beneficiaries.

The list included names such as Ireneo Concha, Braulio de Torres, Lazaro Concha, Segdina Crisostomo, Ambroso Barleta, Raymundo Gayapa, Sofia Rubio, Sosimo Lopez, Segunda Lopez, Lorenzo Navarro, Inang Rubio, Gabriel Concha, Romanita Concha, Benita Cosico, Domingo Garcia, Romeo de Castro, Pedro Concha, Constantino Zita, Rolando Navarro, Rosalinda de Torres, Candida de Torres, Rodelo Cosico, Teodolfo Capuno, Antonio de Torres, and Maxima Concha.

Three Certificates of Land Ownership Awards (CLOA) were subsequently issued in favor of the petitioners, confirming their status as qualified farmer-beneficiaries over a portion of the land.

On March 24, 1995, respondents (Paulino Rubio, Sofia Rubio, Ambrocia Barleta, Segundo Crisostomo, Milagros Gayapa, Lasaro Concha, and Lorenso Navarro) filed a complaint for a declaration of their tenancy, their identification as beneficiaries, and for disqualification of the petitioners.

Respondents alleged that they were tenants who had not abandoned their rights, particularly as they had returned monetary awards given by the landowners.

In response to a joint project between the landowners and a private developer (1st A.M. Realty Development Corporation), the Department of Agrarian Reform (DAR) approved an application on April 26, 1995, for the conversion of the landholding provided that:

Qualified farmer-beneficiaries receive disturbance compensation under R.A. 3844 (as amended by R.A. 6389).
The remaining 18.5006 hectares would be distributed under CARP to qualified farmer-beneficiaries.

Respondents, having been paid disturbance compensation, later questioned the validity and legality of the petitioners’ identification as beneficiaries.
A further case for annulment of the CLOAs and for a preliminary injunction was filed in January 1996, consolidated with an earlier case; both cases were initially heard by the Office of the Provincial Adjudicator (PARAD).

On August 9, 1999, the PARAD dismissed the case citing lack of merit, ruling that the respondents had waived their rights by virtue of their sworn statements (Salaysay and Magkasamang Sinumpaang Salaysay) and that the selection of beneficiaries is an administrative matter under DAR’s jurisdiction.

On November 17, 2000, the Department of Agrarian Reform Adjudication Board (DARAB) set aside the PARAD decision, ordering the cancelation of the CLOAs issued to the petitioners and the reissuance of new ones in favor of the respondents.

Petitioners then filed a Motion for Reconsideration with the DARAB, which was denied on September 6, 2002, leading them to appeal to the Court of Appeals (CA).

On September 9, 2003, the CA issued a decision in favor of the petitioners, reinstating the title issuances as valid.
Respondents filed a Motion for Reconsideration, and on February 27, 2004, the CA amended its decision, reinstating the DARAB decision.

Throughout the proceedings, extensive affidavits and documentary evidence (including that of the MARO) were adduced, detailing:

The voluntary nature of the respondents’ waiver of rights, exemplified by their sworn statements.
The motivations behind the respondents’ actions, with allegations of greed and an attempt to claim a larger share of the land.
The administrative process under CARP involving the identification and selection of beneficiaries, which is documented in the relevant DAR Administrative Orders and implementing rules.

The petitioners raised a sole assignment of error questioning whether the DARAB had jurisdiction to determine the qualified farmer-beneficiaries over the subject land.
Citing previous decisions (notably Lercana v. Jalandoni and Sta. Rosa Realty Development Corporation v. Amante), the petitioners contended that the identification and selection of CARP beneficiaries are strictly administrative functions vested in the DAR Secretary.
The factual record included numerous affidavits and administrative orders that detailed the process of listing beneficiaries and the inherent administrative nature of such functions.

Whether the DARAB is empowered to decide the issue regarding the identification and selection of qualified farmer-beneficiaries under the Comprehensive Agrarian Reform Program.
Whether the determination of beneficiaries, inherently an administrative action under the exclusive prerogative of the DAR Secretary, falls within the jurisdiction of the DARAB or should be deferred to the DAR’s administrative process.

Whether the respondents’ sworn statements, which purportedly amounted to a waiver of their rights as tenants and farmer-beneficiaries, were sufficient grounds to exclude them from the beneficiary list.
Whether the actions of the MARO, in refusing to include the respondents based on these waivers and other affidavits, should be accorded due deference in light of the administrative framework governing CARP.

The impact of the conflicting decisions emanating from the PARAD, DARAB, and the Court of Appeals on the final determination of the rightful beneficiaries of the land.
The proper agency to decide on disputes arising out of the identification and selection process given the overlapping yet distinct jurisdictions of the administrative bodies and the courts.