G.R. No. 262889 - Buenaventura Balucan, Jr. and Yolanda Y. Balucan vs. Lennie B. Nageli and Rudolf Nageli, represented by Eppie B. Fadrigo and Teodorico Fadrigo

Case Summary (G.R. No. 262889)

Relevant Facts

The dispute arose when Sps. Nageli filed a petition with the Department of Agrarian Reform (DAR) seeking to disqualify Sps. Balucan et al. as Agrarian Reform Beneficiaries (ARBs) under the Comprehensive Agrarian Reform Law of 1988, Republic Act No. 6657. Sps. Nageli contended that they were the rightful owners of the land in question, having purchased it from Sps. Jose Neri Rendon and Salvacion Rendon, but that Sps. Balucan et al. obtained ownership through fraudulent means.

Judicial History

The initial order by DAR-Regional Office XI disqualified Sps. Balucan et al. based on their lack of qualification as ARBs, stating they were neither permanent residents nor actual tillers of the land. Following their appeal, the DAR Secretary affirmed the disqualification, leading Sps. Balucan et al. to file a Petition for Certiorari with the Court of Appeals (CA), claiming grave abuse of discretion by DAR.

Court of Appeals (CA) Decision

On July 21, 2021, the CA dismissed Sps. Balucan et al.'s Petition for Certiorari, ruling it was the wrong remedy, as the appropriate recourse was a verified Petition for Review under Rule 43 of the Rules of Court. The CA also highlighted that the petition was filed beyond the reglementary period for such cases.

Supreme Court's Review of the Case

Sps. Balucan et al. subsequently challenged the CA's ruling in the Supreme Court. They maintained that their petition was justifiable due to grave abuse of discretion and the lack of other adequate remedies. The Supreme Court analyzed whether the CA erred in its procedural ruling and whether the DAR had jurisdiction over the disqualification case, which hinged on whether Sps. Nageli were considered real parties-in-interest.

Assessment of Jurisdiction and Remedy

The Supreme Court clarified that a Petition for Certiorari is not appropriate where there exists a remedy in the ordinary course of law, particularly through a Petition for Review. The Court reinforced that the CA acted correctly in dismissing the certiorari petition, emphasizing that cases against the DAR, specifically concerning disqualification of ARBs, must follow the procedures outlined in Republic Act No. 6657.

Disqualification of Sps. Balucan

The Court further analyzed the legitimacy of the claims against Sps. Balucan, particularly regarding the alleged material misrepresentation of their qualifications as ARBs. Although the DAR Secretary's orders to disqualify Sps. Balucan were procedurally correct, the dar's jurisdiction was questioned due to the claim that Sps. Nageli, as foreign nationals, could not initiate the disqualification case.

Conclusion on Jurisdiction

Ultimately, the Supreme Court concluded that the DAR was without jurisdiction in this instance as Sps. Nageli were not considered real parties-in-interest for the disqualification petition they filed. This jurisdictional f