G.R. No. 189570 - Heirs of Nisperos vs. Nisperos-Ducusin

Santiago Nisperos, the predecessor of the petitioners, acquired a 58,350‑square‑meter agricultural land in Pao Sur, San Fernando City, La Union during his lifetime.
The property was declared for taxation purposes beginning December 1947, initially in the name of Maria, one of Santiago’s nine children, with subsequent declarations including Cipriana.

Maria and Cipriana executed, on February 12, 1988, a Deed of Donation Mortis Causa in favor of the heirs over the entire property.
On April 28, 1992, while Maria and Cipriana acted as representatives of the heirs, they executed a Deed of Voluntary Land Transfer (VLT) in favor of respondent Marissa Nisperos-Ducusin, who was then 17 years old.
The VLT was executed in the presence of witnesses, notarized by Notary Public Atty. Roberto E. Caoayan, and subsequently led to the issuance of Certificate of Land Ownership Award (CLOA) No. 0002122453902 on June 24, 1992, and Original Certificate of Title (OCT) No. CLOA-623 on July 24, 1992.

Alleging fraud and irregularities in the execution of the VLT — specifically that the transfer was made without the consent of all heirs and that respondent allegedly took advantage of Maria’s senility — petitioners filed a complaint on September 6, 2001 with the Municipal Agrarian Reform Office (MARO).
Petitioners further contended that the VLT was executed under misrepresentation, with documents being falsified (e.g., the use of a thumbmark by Maria) and that respondent was not a bona fide beneficiary, given her minority and lack of prior farming engagement.

Proceedings Before the Department of Agrarian Reform Adjudication Board (DARAB)

On January 23, 2002, petitioners filed a complaint for annulment of the VLT and the corresponding OCT/CLOA, as well as for damages.
On March 6, 2002, respondent filed a Motion to Dismiss, arguing prescription of the action.
The DARAB Regional Adjudicator, in an order dated October 16, 2002, annulled the VLT and the OCT/CLOA on grounds of irregularities such as the improper consent of all heirs and misapplication of agrarian laws.
Subsequently, the respondent contested the Regional Adjudicator’s decision before the DARAB, arguing issues of prescription, lack of proper parties-in-interest, and asserting that her minority status did not disqualify her from being an agrarian reform beneficiary.

On September 16, 2008, the DARAB reversed the Regional Adjudicator’s decision, upholding the validity of the VLT and the OCT/CLOA, and affirming respondent’s peaceful possession of the subject property.
Petitioners then elevated the case to the Court of Appeals via a petition for review, raising issues on CARP coverage, alleged fraud in the VLT execution, and prescription.
On July 13, 2009, the Court of Appeals rendered a decision dismissing petitioners’ review, sustaining the administrative determinations regarding both fraud and the indefeasibility of the title issued in respondent’s name.

A central point arose as to whether the grievance should have been addressed by the DARAB or properly by the Office of the DAR Secretary, noting that the complaint did not allege an agrarian dispute predicated on a tenancy relationship.
The issue of whether the controversy, involving the cancellation of a CLOA, fell within the jurisdiction of the DARAB – which is generally limited to disputes involving landowner-tenant relationships under agrarian laws – was raised.

Whether the subject property falls within the ambit of the Comprehensive Agrarian Reform Program (CARP) and whether there exists an agrarian dispute between the parties, particularly in the absence of a tenancy relationship.
Whether the VLT executed on April 28, 1992, was invalid due to misrepresentation, fraud, and lack of the necessary consent of all heirs.
Whether the action for annulment of the VLT and the associated documents, including the OCT/CLOA, has already prescribed by the time of the filing of the complaint.
Whether the jurisdiction lies with the DARAB or with the Office of the DAR Secretary, considering that the complaint did not sufficiently allege an agrarian dispute, thus affecting the appropriateness of the forum.