G.R. No. 162890 - Heirs of Dela Cruz vs. Heirs of Cruz

The Republic of the Philippines acquired the De Leon Estate in Barangay Casulucan, Talavera, Nueva Ecija for redistribution to deserving tenants and landless farmers under Commonwealth Act No. 539, as amended by Republic Act No. 1400.
The property was administered by the Land Tenure Administration and later by the Department of Agrarian Reform (DAR).

Around 1950, the DAR allocated a portion of the property, identified as Lot No. 778 (3.362 hectares), to Julian dela Cruz, who was a tenant on the estate.
In September 1960, the Republic of the Philippines sold Lot No. 778 to Julian dela Cruz via an Agreement to Sell, and on September 27, 1960, DAR issued Certificate of Land Transfer (CLT) No. AS-5323 in his favor.
Julian obliged himself to pay the associated amortizations in 30 annual installments while cultivating the lot for approximately 20 years until his death in 1979.

After Julian’s death, his widow Leonora Talaro-dela Cruz and their children, including Mario and Maximino dela Cruz, became his surviving heirs.
Due to her advancing age and poor health, Leonora, on May 1980, executed a private document (with her children’s consent) selling the land to Alberto Cruz, thereby transferring the right to possess, cultivate, and continue the amortization payments under Julian’s Agreement to Sell.
Mario, one of the heirs, conformed to the deed despite acting as the administrator of the landholding.

Alberto Cruz took uninterrupted possession of the lot and cultivated it for about 10 years without protest from Leonora or her children.
He then filed an application with the DAR to purchase the property.
On August 8, 1990, MARO Paterno Revollido prepared an Investigation Report recommending that the land be declared vacant and thereby disposable to a qualified applicant, attaching the deed executed by Leonora in favor of Alberto.

On November 16, 1990, the Provincial Agrarian Reform Officer (PARO) approved the MARO’s recommendation by issuing an Order that canceled Julian’s CLT and declared Lot No. 778 vacant and disposable.
The order directed that a Certificate of Land Ownership Award (CLOA) be issued to Alberto after a 15-day protest period.
The order was disseminated only to Julian (by registered mail) even though he was deceased.
Subsequently, the DAR Secretary issued CLOA No. 51750 on June 27, 1991, which was later recorded and embodied in Transfer Certificate of Title (TCT) No. CLOA-0-3035 issued on August 15, 1991, with an annotation restricting its transfer within 10 years except to the Land Bank of the Philippines.

In early 1996, Maximino, one of Julian’s heirs, discovered the registration of the land in Alberto Cruz’s name.
On October 10, 1996, Leonora and her children filed a petition with the Provincial Agrarian Reform Adjudicator (PARAD) seeking the nullification of:

The petitioners contended that they were deprived of their rights as heirs and that neither the private document executed by their mother nor the subsequent issuance of the CLOA and title conformed with agrarian reform laws and DAR Memorandum Circular No. 8, Series of 1980.

Alberto Cruz defended his title stating he acquired the rights for P51,000.00, took full possession, collected produce, and continued payment of amortizations.
The PARAD ruled in his favor by cancelling the CLOA and ordering a re-issuance in the name of the heirs, also directing Alberto to vacate the property.
This decision was appealed to the DAR Adjudication Board (DARAB) and later affirmed by DARAB on June 19, 2000, based on the argument that the petitioners’ rights were non-transferable except by hereditary succession and that the private document executed by Leonora was tainted by non-compliance with the relevant DAR rules.

The jurisdiction of the DARAB over the case (asserting that the dispute was primarily one of ownership and should be handled by the RTC, not by the DARAB).
Whether the CLOA may be canceled; and
Whether the disputed lot could still be awarded to the petitioners.

The Heirs countered that under Rule VI, Section 1(f) of the DARAB Rules of Procedure the DARAB had jurisdiction over matters involving the issuance, correction, or cancellation of CLOAs, regardless of the tenancy relationship.
The CA eventually dismissed the petition of the heirs for lack of jurisdiction, a decision which was later appealed to the Supreme Court.

Whether the DARAB has the authority to adjudicate the dispute concerning the validity of the November 16, 1990 Order, the issuance, and subsequent cancellation of the CLOA and the title.
Whether the controversy is agrarian in nature, thus falling under the exclusive functions of the DAR or whether it is an issue of ownership best handled by the RTC.

Whether the private document executed by Leonora Talaro-dela Cruz, by transferring the right to possess and cultivate the land to Alberto Cruz, is valid or can be assailed by the heirs who claim non-consent and non-participation.
Whether such deed constituted a waiver of their tenancy or beneficiary rights, potentially barring their claims by laches, prescription, or estoppel.

Whether the actions of the DAR officials (MARO, PARO, and DAR Secretary) in issuing and later approving the CLOA were in conformance with agrarian reform laws (such as R.A. No. 6657, P.D. No. 27, and DAR Memorandum Circulars No. 8 and 19).
Whether the dispute concerning the alleged violation of the petitioner’s substantive and procedural due process rights, as well as the alleged non-compliance with DAR orders, falls squarely within the jurisdiction of the DARAB or if it is a matter for the DAR Secretary.