G.R. No. 221484 - Robustum vs. Department of Agrarian Reform

Petitioner Robustum Agricultural Corporation is the registered owner of a 50,000‐square meter parcel of agricultural land (“subject land”) in Silay City, as evidenced by Transfer Certificate of Title (TCT) No. T-15256.
The subject land formed part of a larger 300,000‐square meter agricultural estate (“mother estate”) previously owned by Puyas Agro, Inc., the petitioner’s predecessor-in-interest.

On December 5, 2013, the Department of Agrarian Reform (DAR), through Provincial Agrarian Reform Officer (PARO) II Teresita R. Mabunay, issued a letter titled “Transmittal of NOC to the Landowner-Transferee/s.”

The letter attached a notice of coverage that identified the mother estate as subject to the agrarian reform program.
It informed petitioner that, as a transferee, it would be included as an “alternative land owner and payee” for purposes of documenting the claim folder, valuation, and compensation proceedings.

Apparently, petitioner refused to receive the letter and the notice of coverage attached thereto.

On June 11, 2014, the DAR issued another notice of coverage that identified both the mother estate and the subject land as covered by the agrarian reform program.

This notice was also published in a newspaper (Philippine Star) on the following day, fulfilling the publication requirement.

On August 14, 2014, petitioner filed a petition for quieting of title and declaratory relief in the RTC of Silay City challenging the efficacy of the notice of coverage.

The petitioner argued that the publication of the notice was improper since it was not personally served and was not posted in conspicuous places as required by DAR Administrative Order (AO) No. 07-11.
Petitioner also contended that Section 30 of RA No. 9700 limited the DAR’s jurisdiction, implying that regular courts should have jurisdiction over cases filed after June 30, 2014.

The DAR and the Land Bank of the Philippines (LBP) objected to the RTC’s jurisdiction, asserting that the issues pertained solely to the implementation of the agrarian reform program—a matter under the exclusive quasi-judicial powers of the DAR defined by Section 50 of RA No. 6657.
The RTC, siding with the DAR and LBP, dismissed the petition on the ground of lack of jurisdiction by issuing Orders dated June 11, 2015, and September 28, 2015.
Petitioner elevated the matter on appeal as a pure question of law, arguing that Section 30 of RA No. 9700 vested jurisdiction to the regular courts for cases initiated after the statutory cut-off date, which in this case was August 14, 2014.

RA No. 6657, as amended, outlines the agrarian reform program and provides for the compulsory acquisition and distribution of private agricultural lands.
RA No. 9700, an amendatory act to RA No. 6657, extended the period for land acquisition and distribution to June 30, 2014 and contains Section 30, which permits the DAR to conclude agrarian reform proceedings that were already pending as of that date.
The issuance of a Notice of Coverage, governed by various DAR administrative orders (including DAR AO No. 07-11), is a critical step in initiating proceedings for compulsory land acquisition and distribution.

Whether the Regional Trial Court (RTC) had jurisdiction to hear and decide the petitioner’s petition for quieting of title and declaratory relief when the matter involves the implementation of the agrarian reform program.
Whether Section 30 of RA No. 9700 limited the DAR’s exclusive jurisdiction in agrarian reform matters to cases pending as of June 30, 2014, thereby vesting jurisdiction on subsequent filings in the regular courts.

The petitioner’s claim that the notice of coverage was ineffective due to improper service—being published in a newspaper without prior personal service—and deficient posting as required by DAR AO No. 07-11.
Whether such procedural defects, if any, strip the notice of its legal effect in triggering the compulsory land acquisition and distribution process.