Case Digest (G.R. No. 200369)
Facts:
Union Bank of the Philippines v. The Honorable Regional Agrarian Reform Officer, et al., G.R. Nos. 203330-31 and G.R. No. 200369, March 1, 2017, Supreme Court Third Division, Jardeleza, J., writing for the Court.Petitioner Union Bank of the Philippines owned two contiguous parcels in Calamba, Laguna (TCT Nos. T-137846 and T-156610). Union Bank submitted the parcels to the Department of Agrarian Reform (DAR) under the Voluntary Offer to Sell (VOS) scheme of the Comprehensive Agrarian Reform Program (CARP). DAR and Land Bank of the Philippines made valuations which Union Bank rejected, prompting DAR to open trust accounts for just compensation while the land remained under administrative processes.
While valuation and VOS-withdrawal requests were pending, DAR officers issued a number of Certificates of Land Ownership Award (CLOAs) in favor of numerous private respondents as agrarian reform beneficiaries and transmitted the CLOAs to the Register of Deeds in September 1993. Union Bank then sought to withdraw its VOS and to have the parcels declared exempt from CARP on the ground of slopes exceeding 18% and lack of development (invoking Section 10 of the Comprehensive Agrarian Reform Law, RA 6657). The DAR Secretary denied the exemption and the motion for reconsideration; Union Bank petitioned the Court of Appeals (CA) under Rule 43, which denied relief in CA-G.R. SP Nos. 114159 and 114354.
Separately, Union Bank filed petitions for cancellation of the CLOAs before the Provincial Agrarian Reform Adjudicator (PARAD) of Laguna. The PARAD dismissed the petitions as premature for lack of a prior determination by the DAR Secretary that the land was exempted; DAR Adjudication Board (DARAB) affirmed the dismissals. Union Bank elevated the DARAB decisions to the CA (CA-G.R. SP No. 116106), and the CA Special Twelfth Division denied the petition, holding among other things that DARAB lacked jurisdiction because the record did not show a tenancy relationship between Union Bank and the CLOA recipients.
Union Bank then filed consolidated petitions for review on certiorari to this Court under Rule 45 (docketed as G.R. Nos. 203330-31 and G.R. No. 200369). The petitions raised principally (a) whether DARAB has jurisdiction to entertain c...(Subscriber-Only)
Issues:
- Does the DAR Adjudication Board (DARAB) have jurisdiction to entertain petitions for cancellation of CLOAs where the parties do not have a tenancy relationship?
- Can the factual findings of the DAR Secretary (e.g., that the land is not exempt from CARP because it is developed) be questioned and re‑weighed in a petition for review o...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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