G.R. No. 147525 - Espinoza vs. Provincial Adjudicator of the Provincial Agrarian Reform Adjudication Office of Pampanga

The dispute involves petitioner Bonifacio Espinoza and private respondent Maria V. Quibuloy, who is the co-owner and administratrix of three parcels of land covered by Transfer Certificate of Title No. 3676.
Quibuloy initiated a complaint for ejectment against Espinoza alleging non-payment of rent and failure to till the land, thereby converting an agrarian dispute into a DARAB (Department of Agrarian Reform Adjudication Board) case.

Proceedings before the Provincial Agrarian Reform Adjudication Office (PARAD)

Petitioner raised a motion to dismiss the case on the ground of lack of jurisdiction.

He cited Section 1, Rule III of the 1989 DARAB Rules, which required parties to submit a certification from the Barangay Agrarian Reform Council (BARC) confirming that the dispute had undergone mediation/conciliation without success.
He argued that respondent’s failure to present the BARC certification should prevent the adjudicator from exercising jurisdiction over the case.

Petitioner (or his counsel) failed to appear on the scheduled date.
As a result, the motion was resolved by default without a formal ruling on its merits.

With petitioner absent, the adjudicator proceeded with the hearing on May 22, 1991.

Quibuloy was allowed to present her evidence ex-parte.
The matter was ordered submitted for decision despite petitioner’s subsequent belated filing of an answer just before rendition of the decision.

In his belated answer, petitioner attacked the respondent’s capacity to sue and provided unsubstantiated denials regarding the non-payment of rent and non-tillage of the land.
The provincial adjudicator, finding Quibuloy’s allegations credible and petitioner’s defenses lacking, rendered a decision against petitioner.

Instead of immediately appealing the adjudicator’s decision, petitioner allowed the reglementary period to lapse.
Subsequently, petitioner filed a petition for certiorari with the Court of Appeals (CA) challenging the decision on several grounds.
The CA dismissed the petition for certiorari, characterizing it as “unavailing and vacuous,” and affirmed that certiorari is limited to questions of jurisdiction rather than errors in the merits or judgment.

Whether the provincial adjudicator erred in proceeding with DARAB Case No. 203-P-90 without the BARC certification, given the jurisdictional requirements under the 1989 DARAB Rules.
Whether the adjudicator should have resolved petitioner’s motion to dismiss before the hearing.
Whether petitioner’s answer was filed out of time and thus should not have been given consideration.
Whether it was proper for the adjudicator to decide in favor of respondent solely on the basis of a self-serving affidavit and the evidence of her lone witness, in the absence of the land title or any document proving her authority as administratrix.
Whether the CA correctly dismissed both the petition for certiorari and petitioner’s motion for reconsideration.

Whether the provincial adjudicator of the PARAD of Pampanga acted within his jurisdiction by proceeding with DARAB Case No. 203-P-90 in the absence of a BARC certification, especially considering the exemption for parties residing in non-adjoining barangays under the 1989 DARAB Rules.

Whether the adjudicator erred in not ruling on petitioner’s motion to dismiss that challenged the lack of the jurisdictional BARC certification prior to scheduling the hearing.

Whether petitioner's filing of his answer after the matter had been submitted for decision renders the answer untimely, thereby justifying not considering it.

Whether the adjudicator erred in deciding in favor of respondent based on the self-serving affidavit of Quibuloy and her lone witness without the presentation of the title (TCT No. 3676) or any document proving her capacity to act as administratrix.

Whether the petition for certiorari, and the subsequent motion for reconsideration, is proper given that certiorari is available only for questions of jurisdiction, and whether petitioner’s negligence in allowing the appeal period to lapse bars his current remedy.