G.R. No. 150207 - Fraginal vs. Heirs of Paranal

The case involves the heirs of Toribia Belmonte ParaAal (Felisa ParaAal, Abraham ParaAal, Pedro ParaAal, Irenea Acabado, and Josefa Estoy) as respondents.
The petitioners, namely Valentin P. Fraginal, Tomas P. Fraginal, and Angelina Fraginal-Quino, are the opposing parties in this dispute.

The heirs filed a complaint with the Office of the Provincial Agrarian Reform Adjudicator (PARAD) of the Department of Agrarian Reform Adjudication Board (DARAB) in Camarines Sur.
The complaint sought:

Termination of the tenancy relationship (i.e., the Agricultural Leasehold Contract dated January 7, 1997).
Ejectment of the petitioners from the land.
Collection of arrear rentals and damages.

Fraginal, et al. responded by filing an answer which questioned the jurisdiction of the PARAD, asserting that:

They were not tenants of the heirs of Toribia ParaAal.
The land they were cultivating was a 1.1408-hectare public agricultural land under the exclusive jurisdiction of the Department of Environment and Natural Resources.

The evidence offered by the petitioners to prove the land’s status as public included a scrap of paper that:

Indicated that a certain area in Pili, Camarines Sur was declared "alienable and disposable" but failed to provide a technical description or clear boundaries.
Claimed to have an attached list of occupants or claimants, although the purported attachment was missing or incomplete.

The Board concluded that the evidence was insufficient and likely presented to confuse the adjudicating authority.

It ordered the ejectment of Fraginal, et al. from the cultivated land.
It terminated the Agricultural Leasehold Contract.
It mandated that the petitioners pay the heirs 54 cavans of palay at 46 kilograms per cavan as arrear rental, covering the period from 1997 until the filing of the case on June 26, 1998, including subsequent rentals until full vacatur.
It issued an order for the petitioners to refrain from disturbing the peaceful possession and cultivation of the land by the heirs.

On April 5, 2001, approximately two years after the issuance of the PARAD Decision, Fraginal, et al. filed a Petition for Annulment of Judgment with a prayer for Preliminary Injunction and/or Restraining Order before the CA.
The petitioners contended that the PARAD Decision was void due to the alleged lack of jurisdiction.
The petitioners also raised the issue of whether Rule 47 of the Rules of Court, which limits annulment proceedings to judgments or final orders of Regional Trial Courts in civil cases, was erroneously applied.

The CA, in its April 24, 2001 Resolution, dismissed the petition on the ground that:

The petition for annulment under Rule 47 was intended only for final judgments or orders of Regional Trial Courts in civil actions and not for quasi-judicial or administrative decisions like that of the PARAD.
The petitioners failed to avail themselves of the remedy provided under Rule 65 of the Revised Rules of Court, although they claimed nonfeasance or untimeliness without fault.

The CA further denied the Motion for Reconsideration dated September 3, 2001, affirming the dismissal of the petition.

Whether the CA erred in dismissing the petition filed for annulment of the PARAD Decision on the ground that the adjudicating body lacked jurisdiction because the land in issue is public agricultural land.
Whether the CA erred in holding that Rule 47 of the Rules of Court is applicable only to judgments, final orders, and resolutions rendered in civil actions of Regional Trial Courts—and does not extend to quasi-judicial or administrative decisions such as that of the PARAD.