Case Digest (G.R. No. 186432)
Facts:
In 849 Phil. 30, the Department of Agrarian Reform (DAR) Secretary, its Region VIII Regional Director, the Provincial Agrarian Reform Officer of Leyte, the Municipal Agrarian Reform Officer of Tabango, and the Register of Deeds of Leyte (collectively, Petitioners) sought review of the Court of Appeals’ reversal of administrative rulings that had voided emancipation patents and certificates of title covering 22.8409 hectares of a 182-hectare parcel purchased in 1983 by Spouses Redemptor and Elisa Abucay from Guadalupe Cabahug. In 1986, pursuant to Presidential Decree No. 27, that 22-hectare portion was covered under the Operation Land Transfer Program, after which farmer-beneficiaries received emancipation patents subsequently registered as titles. On June 28, 2002, the Abucay heirs filed before the Regional Agrarian Reform Adjudicator (RARAD) a complaint for just compensation, arguing they inherited the land and had not been paid adequate compensation. In April 2004 they filed aCase Digest (G.R. No. 186432)
Facts:
- Parties and Land Transaction
- Petitioners: Secretary of the Department of Agrarian Reform (DAR), DAR Regional Director, Region VIII, Provincial Agrarian Reform Officer of Leyte, Municipal Agrarian Reform Officer of Tabango, Leyte, and Register of Deeds of Leyte.
- Respondents: Heirs of Redemptor and Elisa Abucay (Rena B. Abucay et al.), who inherited a 182.9698-hectare parcel covered by TCT No. T-9814 purchased by their parents in 1983 from Guadalupe Cabahug.
- Agrarian Reform Coverage and Titles
- October 14, 1983: Deed of Absolute Sale conveyed the 182-ha to Spouses Abucay, noting 39.459 ha tenanted and under potential Operation Land Transfer (OLT) coverage.
- 1986: 22.8409 ha declared covered by OLT (PD 27); emancipation patents (EPs) issued to farmer-beneficiaries and registered as original certificates of title (OCTs) with the Register of Deeds.
- Administrative and Judicial Proceedings
- June 28, 2002: Heirs file Complaint before Regional Agrarian Reform Adjudicator (RARAD) for just compensation and cancellation of EPs/OCTs, alleging lack of notice to registered owner and inadequate compensation.
- June 16, 2005: RARAD Decision voids EPs/OCTs and OLT coverage for failure of administrative due process.
- May 10, 2006: DAR Adjudication Board (DARAB) reverses and dismisses for lack of jurisdiction, treating the case as an agrarian law implementation (ALI) protest under the Regional Director’s primary jurisdiction.
- September 26, 2008: Court of Appeals (CA) reverses DARAB, reinstates RARAD Decision, holds RARAD/DARAB have jurisdiction over cancellation of registered EPs.
- April 7, 2009: Separate petitions for certiorari filed before the Supreme Court (G.R. Nos. 186432 & 186964), later consolidated.
Issues:
- Did the RARAD and the DARAB have jurisdiction over the Complaint for cancellation of registered EPs and OCTs?
- Did the Heirs of Abucay have legal personality to file the cancellation Complaint?
- Were the OLT acquisition proceedings for the 22.8409-ha void for lack of administrative due process?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)